CUSTOMER AND DIRECT MARKETING REGISTER PRIVACY POLICY
DATA COLLECTOR
Marketing Agency Kuubi Ltd. ("Kuubi" or "we") processes personal data of its customers for the purpose of managing customer relationships, fulfilling contractual obligations, maintaining its CRM system, customer communication, and direct marketing. In addition to current customers, Kuubi may process personal data of potential customers.
Below, we provide more information about the processing of personal data.
Please note that this privacy policy ("Privacy Policy") applies only to the processing of personal data of corporate customers carried out by Kuubi as the data controller.
DATA CONTROLLER CONTACT INFORMATION
• Marketing Agency Kuubi Ltd.
• Business ID: 1760653-5
• Address: Kaikukatu 2 C, 2. Floor, 00530 Helsinki
• Phone number: +358 50 594 3652
• Email address: anna.porvari@kuubi.fi
• Person responsible for the customer register: Anna Porvari
PROCESSED PERSONAL DATA AND SOURCES OF INFORMATION
We collect customer-related information ("Customer Data") and technical analytics data ("Analytics Data") from our customers.
Although we do not usually use Analytics Data to identify individuals, in some cases, individuals may be identifiable either alone or when combined or linked with Customer Data. In such cases, Analytics Data is considered personal data in the sense defined by applicable legislation, and we process the combined data as personal data.
Kuubi collects and processes the following Customer Data:
first and last name;
represented organization;
position in the organization;
email address;
phone number;
communication;
billing and payment information;
consents or prohibitions related to direct marketing or other information; and
other information provided by the customer or added to the CRM system (e.g., expressed interest in certain types of services).
Most of the Customer Data is obtained directly from the customer or the data subject themselves. In addition, personal data may be collected and updated from various data services and public registers.
Analytics Data collected and processed during the use of our website includes the following information:
customer's IP address;
customer's device and device identifier;
operating system;
visit times;
URL route on the website;
browser type and version; and
language settings.
COOKIES AND WEB ANALYTICS
Kuubi may use cookies and other technologies to collect Analytics Data when you visit our website.
A cookie is a small text file sent to and stored on the user's computer that allows the website administrator to recognize frequent visitors to the site, facilitate the use of visitor services, and compile aggregated information about visitors. With this feedback, we can constantly improve our website and better serve our customers. Cookies do not harm users' computers or files. We use them to provide personalized information and services tailored to our customers' individual needs.
You can prevent the use of cookies in your browser or set your browser to notify you when cookies are being installed. For example, the following links provide information on changing cookie settings in popular browsers:
Safari
Google Chrome
Internet Explorer
Mozilla Firefox
Please note that our website may not function properly if the use of cookies is disabled.
We use Google Analytics and other web analytics tools on our website to collect Analytics Data and reports on visitors' use of our website. For more information about Google Analytics, visit the Google Analytics website. You can refuse the collection of data by Google Analytics by downloading the following browser add-on: Google Analytics opt-out add-on.
PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING
Purposes
Kuubi processes personal data for the following purposes:
Service provision
We process personal data primarily to provide services to our customers and to conduct, maintain, and develop our business. Personal data may be used to fulfill our contractual obligations to the customer. If a customer contacts our customer service, we use the provided information to respond to inquiries and resolve any issues.
Customer communication and marketing
We may process personal data to contact customers regarding matters related to our services, to notify customers of changes to the services, to process and collect customer feedback, and to market our services.
Visitor analytics and trend identification
We may process information about the use of the services to improve the quality of our services, for example, by analyzing various trends and developments related to the use of the services. To this end, we use anonymized or pseudonymized data whenever possible, where individuals cannot be identified.
Legal basis for processing
We process personal data based on our legitimate interests to conduct, maintain, and develop our business, and to create and maintain customer relationships. When processing your personal data based on our legitimate interests, we balance our legitimate interests against your right to privacy.
In addition, we process personal data to fulfill our legal obligations, such as the documentation obligations imposed on us by accounting laws.
In some situations, we may request your consent for the processing of personal data. In such cases, the consent given can be revoked at any time.
RETENTION PERIOD
We retain personal data only for as long as required by law or as necessary to fulfill the specified purposes.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
Kuubi generally stores personal data within the European Economic Area.
However, our service providers operate in multiple geographic regions. We and our service providers may transfer personal data or access it from countries outside the European Economic Area or your country of residence.
In such cases, we ensure that the level of protection for personal data is adequate in the areas where personal data is processed. We provide adequate safeguards for the transfer of personal data to countries outside the European Economic Area with our service providers based on the model contract clauses approved by the European Commission or in accordance with any other arrangement approved by the European Commission, such as the Privacy Shield program.
RECIPIENT GROUPS OF PERSONAL DATA
We do not disclose personal data to external parties outside of the Kuubi organization, except in the following situations:
Sharing is necessary for the purposes specified in this Privacy Policy.
To the extent that third parties need access to personal data to perform services, Kuubi has implemented appropriate contractual and organizational measures to ensure that the processing of personal data is carried out solely for the purposes mentioned in this Privacy Policy and in accordance with applicable laws and regulations.
For legal reasons
We may disclose personal data to third parties outside the Kuubi organization if access to the personal data and its use is reasonably necessary to (i) comply with any applicable laws, regulations, and/or court orders; (ii) detect, prevent, and address fraud, security issues, or technical issues; and/or (iii) safeguard the interests or property of Kuubi or our customers, or for the security and protection of the public in accordance with the law. If possible, we will inform customers of such transfers and processing.
To authorized service providers
We may disclose personal data to authorized service providers who provide services to us (including subcontractors providing storage, sales, marketing, and customer support services). In accordance with the commitments included in our agreements with service providers, the service providers undertake to comply with at least the privacy and data security standards stated in this Privacy Policy. Please note that when you provide personal data directly to a third party through a link on our website, for example, the processing of personal data is typically based on the third party's own documentation and standards.
With explicit consent
We may disclose personal data to third parties outside our organization for purposes other than those mentioned above when we have the explicit consent of the customer. The customer has the right to withdraw consent at any time.
For other legitimate reasons
If Kuubi is a party to a merger, business acquisition, or other corporate transaction, we may disclose personal data to the third party involved in that corporate transaction. However, we ensure that all personal data remains confidential. In this case, we will inform the customers whose personal data is being transferred or whose personal data processing is subject to a different privacy statement as soon as reasonably possible.
RIGHTS OF THE DATA SUBJECT
Right to access information
Data subjects have the right to access their personal data processed by Kuubi. You can contact us to find out what personal data we process and for what purpose.
Right to request rectification of information
You have the right to request the correction or supplementation of inaccurate, incomplete, outdated, or unnecessary personal data we retain. By contacting us, you can update, for example, your contact information.
Right to request erasure of information
You can request us to erase your personal data. We will take action as requested unless we have legitimate grounds for retaining the information.
Right to object and restrict processing
You have the right to object to the processing or profiling of your data if your data is processed for direct marketing purposes. You also have the right to request the restriction of the processing of your personal data, for example, when the information concerning you is inaccurate. In addition, you have the right to object to the processing of your personal data in certain specific situations based on personal circumstances.
Right to data portability
Data subjects have the right to receive their personal data from us in a structured and commonly used format and to independently transfer the data to a third party.
Exercising the rights
If you want to exercise any of the above rights, please send the following information by mail or secure email: name, address, phone number, and a copy of a valid identification document. We may request additional information to verify your identity.
We may reject requests that are made unreasonably frequently, are excessive, or are clearly unfounded.
DIRECT MARKETING
We may send you newsletters about our services and other direct marketing materials.
Data subjects always have the right to refuse us from using their personal data for direct marketing, market research, or profiling by contacting us using the contact details provided above or by using the unsubscribe option provided in the direct marketing messages.
DATA SECURITY
We have implemented administrative, organizational, technical, and physical security measures to protect the personal data we collect and process. Our security measures are designed to maintain an appropriate level of confidentiality, integrity, and availability of the data.
Personal data can only be processed by individuals for whom this is justified in terms of their job responsibilities. The use of personal data is protected by appropriate user-specific usernames, passwords, and access rights.
FILING A COMPLAINT
You have the right to file a complaint with the supervisory authority if you believe that the processing of Kuubi's personal data is in violation of data protection laws.
Last updated: March 24, 2022