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ILONA WORKS FINLAND OY

Privacy Policy 2018

1. Our commitment to privacy

Your privacy is very important to us at Ilona Works Finland Oy (hereinafter also “we”, “us” and/or “IlonaWorks”).  In order to better protect your privacy, we deliver you this policy (“Privacy Policy”), where we explain how we collect and use your information. We advice you to read this Privacy Policy and to ensure that you understand our practices with respect to processing personal data before you use our services.

The purpose of this Privacy Policy is to offer you a clear clarification of what personal data we collect, when, why and how we collect, use and distribute your personal data and what are your statutory rights. The purpose of this Privacy Policy is not to annul the terms and conditions of the agreement you have concluded with us, nor any rights that you may have under applicable data protection laws.

2. Controller

Ilona Works Finland Oy acts as the controller for information collected and processed in different Ilona Works –services. The contact details for IlonaWorks are the following:

Ilona Works Finland Oy
Itälahdenkatu 22b
00210 Helsinki
Finland
Tel. +358 (0) 50 318 8010
Email. info@ilona.works

3. What information do we collect and how we collect it?

We collect the following information of persons using and registering to our Ilona Works –services:

  • Name of the person (first and last name)
  • Contact details (email, phone, address)
  • Personal identification number
  • Salary amount
  • Employer company
  • Information on the person’s authority to sign for the employer company
  • IP- and MAC –addresses as well as other technical identifiers (such as cookie IDs)

We collect your personal data primarily directly from you when you order, log in or register to our Ilona Works –services. We may also receive some of your personal data (such as information of your salary) from your employer company when it acquires services that also concern you through our Ilona Works –services, as well as from certain third parties that provide personal data, such as credit and company data service providers (concerning information of your authority to sign). Your employer company and the abovementioned third parties apply their own principles and policies concerning personal data in their processing of personal data, and Ilona Works cannot affect the processing of your personal data by such parties.

We collect technical identifiers through different cookies on our website and in our IlonaWorks –services when you visit our website or our IlonaWorks –services. You can find more information on the cookies we use below in this Privacy Policy.

We will always make sure that we have appropriate legitimate grounds in accordance with the applicable legislation to process your personal data. The processing of your personal data is based either on: a) the execution and fulfilment of an agreement you have concluded with us, b) our legitimate interests, such as the appropriate performance and development of our services, or c) your consent, when we have separately and expressly requested it.

4. How do we use your personal data?

4.1 To offer our products and services

We process and collect your personal data in order to be able to offer our services and their functions. We may use the information we have collected on you to create a user account for you, confirm your order, and offer the services you have requested or ordered. If necessary, we will also use your personal data to offer customer service and to forward your order to our partners.

We will also use this information for the purposes of customer management, such as to maintain a customer relationship with you as well as to improve your customer experience.

4.2 To verify your identity and authority to sign

We may use information collected from you to verify your identity and the existence of your authority to sign. Several of our IlonaWorks –services provide an opportunity to order services from third parties acting as our partners via the use of our own services, which is why we have to ensure that you have a right to enter into agreements and make orders on behalf of the company you represent. We may also use this information to establish or create an account for you, to verify or provide you a new password, to register your activities and to contact you from time to time.

4.3 For internal business purposes

We may process your personal data to improve and develop the services we offer to you as well as to tailor your browsing experience. Some of the information (especially information collected with cookies and other tracking tools) helps us to improve the functionality and usability of our website. In addition, when necessary, we may use your personal data to track fraudulent and other inappropriate actions, and to monitor the integrity of the content in our IlonaWorks –services and our website.

4.4 To communicate with you

We use your personal data to answer your queries and complaints about our services, as well as to offer you important information of your account and your services. Such communication purposes may include, for example, a notification that your order has been processed.

5. Marketing

We may use your personal data (such as your email address) for marketing purposes. For example, we may send you emails to notify you about news and updates concerning IlonaWorks –services, or to market new solutions and products that have become available through our IlonaWorks –services.

Primarily, we direct all such marketing to your employer company and your role in the company, in which case we do not generally need a separate consent for marketing. However, when required by law, we will obtain your consent before sending such marketing communication. We will also provide you an opportunity to decline (so-called opt-out) marketing when you receive marketing communications from IlonaWorks.

You have a right, at any time, to prohibit our marketing directed at you. You can prohibit marketing either by unsubscribing by clicking the unsubscribe –link that can be found in each of our marketing communication, by changing the privacy settings of your IlonaWorks –service account, or by sending an email to our email address provided above.

6. How do we protect and retain your personal data?

6.1 Information security

We shall always ensure by the use of appropriate technical and organizational information security measures that your personal data processed by us are protected and secured from loss, unauthorized access and use as well as other corresponding security breaches and data leakage. These actions may include, inter alia, setting confidentiality requirements for our personnel and service providers, restrictions on access rights, anonymization and pseudonymization of data, use of firewalls and antivirus software, lock-up storage spaces as well as secure server facilities. If an information security threat has affected your personal data processed by us, we ensure that the appropriate measures required by law are carried out to remove the threat and mitigate its effects.

However, the security of your personal data also depends partly on you. You shall ensure that the devices and internet connection used by you in connection with IlonaWorks –services are appropriately encrypted. You shall also ensure that you keep your user name and password to our IlonaWorks -services confidential and you do not share your user name, user ID or password with any other person.

6.2 Retaining personal data

We will retain your personal data as long as you have a customer relationship with us or as long as it is otherwise necessary in order to provide our services appropriately. After this, we will retain your personal data as long as we are obligated to do so under applicable legislation (for example concerning retaining invoices or the requirements under accounting legislation), or as long as it is necessary in order to be able to defend against possible legal claims.

7. How do we disclose and transfer your personal data

IlonaWorks may, from time to time, disclose and transfer your personal data to certain third parties (or otherwise grant them access to personal data) in connection with IlonaWorks –services. Such third parties are, inter alia, our subcontractors and other service providers that participate in producing IlonaWorks –services or to whom we have otherwise outsourced our activities (for example our invoicing services or marketing services). However, we do not sell your personal data to third parties for any marketing purposes.

In addition to what has been mentioned above, we disclose your personal data to those third parties acting as our partners whose products or services you wish to order through our IlonaWorks –service. However, such third parties acting as our partners process the personal data we have disclosed independently as controllers in accordance with their own privacy policies and personal data processing practices. By ordering services or products of our partners, you acknowledge that these parties process your personal data and IlonaWorks cannot affect the processing measures of these third parties.

IlonaWorks processes and retains personal data mainly within the European Union (EU) and the European Economic Area (EEA), and personal data is not transferred outside these areas. However, some of our service providers or server services used by us may, from time to time, be located also outside the EU or the EEA. In these cases personal data may also be processed in such countries outside the EU or the EEA, where the level of data protection is not necessarily the same as in your own home country. If we transfer or allow access to your personal data from such countries, we will always ensure the protection of your personal data in connection with transfers by using appropriate safeguards determined by applicable laws. Such safeguards may be the EU-US Privacy Shield certification or entering into the standard contractual clauses of the EU commission.

You have a right to contact us in order to receive more information of the safeguards (including a copy of appropriate safeguards of transfers) used by us in order for you to ensure that your personal data is sufficiently protected when it is transferred in accordance with the abovementioned.

8. Use of cookies

  • IlonaWorks uses certain cookies in connection with its IlonaWorks –services and its website. These cookies are used so that we can continuously maintain and improve our services as well as in order to offer a better user experience for our customers. With the help of cookies we can, for example, maintain and track our customers’ preferences, secure our services better, identify technical problems as well as monitor the overall performance of our services.

8.1 The cookies we use

We use cookies on our website and IlonaWorks –services to track the information your browser provides us in connection with your visits. Cookies are small text files that may be uploaded and stored on your devices, and which enable the use of the internet and functionalities of some services for example on your computer, smartphone or tablet. IlonaWorks uses several different cookies.

We use the following cookies on our website:

  1. Strictly necessary cookies

Strictly necessary cookies are by definition necessary for functioning of the services and their purpose is to help you on our website and in the use of our IlonaWorks –services. These cookies help to improve the security and basic functions of our services and they are strictly necessary for the functioning of our website and IlonaWorks –services. If you block these cookies, we cannot guarantee your use or security during your visit.

  1. Functionality cookies

We use functionality cookies in order to offer you the best user experience. These cookies are used, for example, to tailor our website or IlonaWorks –services for you. With the help of these cookies, our website and services remember the choices you have made in order to offer you more personalized functions.

  1. Performance cookies

Performance cookies help us to understand the behavior of the users of our website and services. With the help of these cookies we can continuously improve our services. We also use these cookies to better understand, how efficiently our website and IlonaWorks –services work. The cookies tell us for example, to which websites out visitors in most cases go and do they receive error messages from the websites.

Third parties administer all of the cookies used by us. You can see the privacy policies of these third parties in order to receive more information on their processing of personal data. We especially use Google Analytics, through which we can evaluate how our website and IlonaWorks-services are used. This information is necessary in order for us to be able to continuously improve the functionality of our website. Cookies may be stored from 30 minutes up to two years. The information that these cookies create on your use of our website (including your IP address) are transferred to Google Inc. and stored in its servers in the United States.

Manage your cookie settings:

You may at any time block or prohibit the use of cookies on your browser settings. However, if you block all cookies, you may not be able to use all features or functionalities of our websites or IlonaWorks –services. More information on managing cookies and deleting them may be found at http://www.allaboutcookies.org/manage-cookies/.

9. Your rights

Applicable data protection legislation guarantees several right for you in connection with the processing of your personal data. With certain additional preconditions and exceptions as well as what is stated elsewhere in this Privacy Policy, you have the following rights listed in this section:

  1. right to request us to provide you a copy of personal data that we have about you and certain information concerning processing of this personal data;
  2. right to request the restriction of processing in certain situations, for example when you contest the accuracy of personal data or we no longer need the personal data for the original purposes of processing but they are necessary for the establishment, exercise or defense of legal claims;
  3. right to request the erasure of personal data in certain situations, for example when the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (so-called right to be forgotten);
  4. right to object processing that is based on our legitimate interest;
  5. right to withdraw consent provided for the processing at any time when our processing is based on your consent;
  6. right to request that we update or rectify inaccurate personal data we hold on you. In some of our IlonaWorks –services you can also rectify, update or delete certain personal data by yourself or deactivate your IlonaWorks –service account completely through your account settings; and
  7. right to lodge a complaint to local competent supervisory authority, which in Finland is the Data Protection Ombudsman (www.tietosuoja.fi).

You can exercise your above-mentioned rights by contacting IlonaWorks by using the contact information provided in this Privacy Policy or in some cases through your user account. We may have to request further information before we can fulfil your request concerning your rights. We request further information in order to verify your identity and to maintain the security of our services.

10. Amendments to this Privacy Policy

We may update and amend this Privacy Policy from time to time. If the amendments concern essential changes in our processing of personal data, we will inform you in advance. In other respects, the updated version is published on our website or otherwise in connection with the IlonaWorks –services. Please check this Privacy Policy regularly in order to see the latest version.