Privacy statement – DRAFT
- Who we are
The processing owners of your details are:
WARMIA OY – Lämmittäjänkatu 2, 20780 Kaarina
The data processor of your data is Warmia Oy.
- Why we collect your personal information
Our primary goals in collecting information are to provide our customers and other users with superior service and a smooth, efficient and personalised experience while using the sites and mobile applications. For example, if you purchase products or request information on the sites, we can use your personal information to fill your order or provide the requested information.
WARMIA may collect personal Information from you to complete various transactions, such as:
- product or service orders, activations and registrations
- profile creation
- information requests
- marketing or support subscriptions
- contest entries or survey participation
- What information is collected? (Precise categories of personal data the app wants to collect and process)
WARMIA collects and uses your personal information to better serve you and personalise your experience and interaction with WARMIA. Such collection is done with appropriate notice and consent, along with required filings with data protection authorities, where applicable.
Personal information (or personal data) means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.
This privacy statement does not cover personal information rendered anonymous or where pseudonyms are used. Data is rendered anonymous if individual persons are no longer identifiable or are identifiable only with a disproportionately large expense in time, cost, or labour. The use of pseudonyms involves the replacement of names or other identifiers with substitutes, so that identification of individual persons is either impossible or at least rendered considerably more difficult. If data rendered anonymous becomes no longer anonymous (i.e., individual persons are again identifiable), or if pseudonyms are used and the pseudonyms allow identification of individual persons, then this privacy statement will again apply.
It is always up to you whether to disclose personal information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services.
The types of personal information we collect from you may include:
- your name, company, email address, phone number, billing address and shipping address, coarse/fine location
- customer type, job function, job title, purchasing authority, purchasing timeframe and others
- product and service preferences, contact preferences, educational and employment background, and job interest data
- your WARMIA user ID and password (where applicable)
- credit card information (where applicable)
- IP address (see chapter on cookies)
- How We Use Your Information
We gather and use information in a number of ways, including the following:
Browsing and Searching: We collect certain Personal Information when you visit the sites or click on the various links for products and services, both from within the website and mobile applications. We collect this information to improve your user experience for your next visits (ex: country selection), help run the sites more efficiently, to gather broad demographic information, to monitor the level of activity on the sites, and to evaluate the effectiveness of our advertising. (See chapter 8 about cookies)
Location: We may collect certain Personal Information (ex: GPS location) when you use some functionalities of mobile applications. We collect this information to improve your user experience (ex: weather conditions forecast).
Ordering: We collect Personal Information when you purchase products and services. We collect this information to deliver your order, to obtain payment, and to communicate with you about the status of your order.
Technical support: We may collect certain information when you request technical support for WARMIA products and services. This information is necessary to identify your systems, understand the configuration of the products, diagnose your questions, and provide solutions.
Online surveys and polling: We collect Personal Information from customers who volunteer to complete surveys or participate in polls. We use this information to improve our products and services.
Promotional activities: We collect Personal Information from you when you enter a promotional program or activity. We use this information to administer the program or activity, to send you promotional e-mails, notify winners, and make the winners’ list publicly available pursuant to applicable regulations and laws.
Newsletters and promotional e-mails: We collect Personal Information when you ask to receive newsletters, promotional e-mails, and other information. We use this information to provide you the information you request.
Contact information: If you contact us, we keep a record of your correspondence or comments, including Personal Information, in a file specific to you. We use this information to help us provide you better service in the event you contact us again.
We may keep your information for a reasonable period for the purposes set out above.
- How do we use your information for marketing?
We (including our group companies) and carefully selected third parties may use the information we collect to inform you, by letter, fax, phone, SMS and email about promotions, news and new products and services that we think may be of interest to you. By providing us with your information you consent to being contacted by these methods for these purposes. If you do not wish to receive marketing information from us please indicate this where requested on the registration or request form.
- What we do with your personal data/ which data will be disclosed to third parties
If you do provide personal information to us, either directly or through a reseller or other business partner, we will:
- not sell or rent it to a third party without your permission — although unless you opt–in, we may use your contact information to provide you with information we believe you need to know or may find useful, such as (for example) news about our services and products and modifications to the Terms of Service;
- take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;
- not use or disclose the information except:
- as necessary to provide services or products you have ordered, such as (for example) by providing it to a carrier to deliver products you have ordered;
- in the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
- as required by law, for example, in response to a subpoena or search warrant;
- to outside auditors who have agreed to keep the information confidential;
- as necessary to enforce the Terms of Service;
- as necessary to protect the rights, safety, or property of WARMIA, its users, or others; this may include (for example) exchanging information with other organisations for fraud protection and/or risk reduction.
- Your content
By providing us with your personal information and using the sites, you consent to our processing your personal data and sensitive personal data for the above purposes. You also consent to our transferring your information to countries or jurisdictions which do not provide the same level of data protection as the EU, if necessary for the above purposes. If we do make such a transfer, we will, if appropriate, put a contract in place to ensure that your information is protected. If you provide us with information about another person, you confirm that they have appointed you to act for them, to consent to the processing of their personal data including sensitive personal data and that you have informed them of our identity and the purposes (as set out above) for which their personal data will be processed.
A cookie is a piece of information in the form of a very small text file that is placed on an internet user’s hard drive. It is generated by a web page server, which is basically the computer that operates a web site. The information the cookie contains is set by the server and it can be used by that server whenever the user visits the site. A cookie can be thought of as an internet user’s identification card, which tell a web site when the user has returned.
If you want to delete any cookies that are already on your computer or to stop cookies being accepted in future you should refer to your browser manufacturer’s instructions by clicking “Help” in your browser menu. More information is available at www.AboutCookies.org.
- How we protect your information
WARMIA is committed to taking appropriate technical, physical, and organizational measures to protect its Employees and Customers Personal Data against unauthorized access, unlawful processing, accidental loss or damage, and unauthorized destruction.
We offer the use of a secure server to enable you to place orders or access your account information. This encrypts your information before it is sent to us.
We also take appropriate measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
We limit access to our internal systems that hold Personal Data to a selected group of authorized users who are given access to such systems through the use of a unique identifier and password. Access to Personal Data is limited to and provided to individuals for the purpose of performing their job duties.
However we cannot guarantee the security of any data you provide to us and you accept the inherent risks of on-line correspondence and purchases over the internet. Any purchases made by you via the Sites are subject to the terms and conditions contained on the Sites.
- Links to third-party websites
We may also provide social media links that enable you to share information with your social networks and to interact with WARMIA on various social media sites. Your use of these links may result in the collection or sharing of information about you, depending on the feature. We encourage you to review the privacy policies and settings on the social media sites with which you interact to make sure you understand the information that may be collected, used, and shared by those sites.
- Your rights to access
As data subjects you may inquire as to the nature of the Personal Data stored or processed about you by any WARMIA entity. You will be provided access to your personal data regardless of the location of the data processing and storage.
A WARMIA entity processing such data will cooperate in providing such access to you either directly or through a local entity. All such requests for access may be sent to:
WARMIA Data Privacy Officer
Lämmittäjänkatu 2, 20780 Kaarina (Finland)
If your Personal Data is inaccurate or incomplete, you may request that the data be amended.
- Change in this privacy statement
WARMIA reserves the right to modify this privacy statement as needed, for example, to comply with changes in laws, regulations, WARMIA practices and procedures, or requirements imposed by data protection authorities.
In this case, WARMIA will inform WARMIA candidates, Customers and other persons of any material changes in this privacy statement. WARMIA will post all changes on relevant internal and external websites.
This statement and the policies referred herein are not intended to and do not create any contractual or other legal rights.
Last update: 28/04/2017