Privacy Policy

Emooter Ltd (Business ID: 2801778-7) ("Emooter", "we"), collects personal data of its customers' employees and users of Emooter's website and service whilst providing its services.

Emooter processes the collected personal data with due care and in accordance with all applicable laws and regulations.

Our Privacy Policy explains what data we process, how we do that, and how the data subjects may use their rights (e.g. right to object, right of access).

This Privacy Policy constitutes a description of the data file as set out in the Finnish Personal Data Act (Sections 10 and 24).

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website www.emooter.com/privacy. This Privacy Policy applies to all personal data that Emooter processes during the execution of our services.

This Privacy Policy only covers data processing carried out by Emooter. The Privacy Policy does not address and we are not responsible for, the privacy practices of any third parties.

EMOOTER'S CONTACT DETAILS

PERSONAL DATA PROCESSED AND SOURCES OF DATA

Emooter collects two types of information from the employees of its customers and the users of Emooter's website and Emooter's services ("Users"): (i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.

Emooter may collect and process the following User Data from Users: (i) first and last name; (ii) address details, (iii) telephone number, (iv) e-mail address, (v) date of birth, (vi) other personal data Users provide themselves, including pictures, for example when creating a profile, (vii) information that Users provide when rating our services or giving feedback on our services, (viii) other data on Users which Emooter's customer enters to the service.

Emooter collects User Data solely in connection with the use of Emooter's service and website.

Cookies

We use various technologies to collect and store information when Users visit the Emooter website, including cookies. Cookies allow us to calculate the aggregate number of people visiting our websites and monitor the use of the websites. This helps us to improve our websites and better serve our users. We also use cookies that make the use of the website easier, for example by remembering usernames, passwords and (language) preferences. We also use tracking and analytics cookies to see how well our services are being received by our users.

Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. Please note that some parts of our sites and services may not function properly if use of cookies is refused. For more information about cookies and how to delete them, visit www.allaboutcookies.org.

Our sites use Google Analytics and other web analytics services to compile Technical Data and reports on visitor usage and to help us improve our sites and services. For an overview of Google Analytics, please visit http://www.google.com/analytics/. It is possible to opt-out of Google Analytics with this browser add-on tool: https://tools.google.com/dlpage/gaoptout.

PURPOSES AND LEGITIMATE GROUNDS FOR THE PROCESSING OF PERSONAL DATA

Purposes

There are several purposes for the processing of personal data by Emooter:

To provide our services and carry out contractual obligations

Emooter processes personal data in the first place to be able to deliver services to its customers and Users and to run, maintain and develop Emooter's business. Emooter uses personal data in order to conduct its contractual obligations. Emooter uses the data for example to offer essential functionalities of the service and to provide customers with analyses and reports. If Users contact our customer service, we will use the provided information in order to answer questions or solve complaints.

For customer communication

Emooter may process personal data to contact customers and Users regarding our services and to inform customers and Users of changes to our services and products. Data may also be used for research and analysis to improve our services and websites.

For quality improvement and trend analysis

Emooter may process information about the use of the services to improve the quality of our services e.g. by analysing any trends in the use of our services. When possible, we will do this using only aggregated, non-personally identifiable data.

Legitimate grounds for processing

Emooter processes personal data to perform our contractual obligations and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to maintain and develop our businesses.

TRANSFER TO COUNTRIES OUTSIDE EUROPE

Emooter does not transfer any personal data to countries outside the European Union and the European Economic Area.

RECIPIENTS

We only share personal data within the organisation of Emooter if and as far as reasonably necessary to perform and develop our services.

We do not share personal data with third parties outside of Emooter's organization unless one of the following circumstances applies:

It is necessary for the purposes of this Privacy Policy

To the extent that third parties need access to personal data to perform the services, Emooter has taken the appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

For legal reasons

We may share personal data with third parties outside Emooter's organization if we have a goodfaith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Emooter, our users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.

For other legitimate reasons

If Emooter is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all customers and Users concerned before the personal data are transferred or become subject to a different privacy policy.

With explicit consent

We may share personal data with third parties outside Emooter's organization for other reasons than the one mentioned before, when we have the data subject's explicit consent to do so. The data subject has the right to withdraw this consent at all times.

STORAGE PERIOD

Emooter does not store personal data longer than is legally permitted and necessary for the pur-poses of providing the services. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use. In general, Emooter deletes all personal data of Users when the relevant customer relationship ends and when Emooter no longer provides services for User's employer or when the User no longer uses the services provided by Emooter.

DATA SUBJECTS' RIGHTS

Right to access

Emooter offers access for the data subjects to the personal data we process. This means that the data subject may contact us and we will inform what personal data we have collected and processed regarding the said data subject and the purposes such data are used for.

Right to correct

Data subjects have the right to have incorrect/imprecise, incomplete, outdated, or unnecessary personal data we have stored about the data subject corrected or completed by contacting us.

Right to deletion

Data subjects may also ask us to delete the data subject's personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data have been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems. Such copies shall be deleted as soon as reasonably possible.

Right to object

Data subjects may object to certain use of personal data if such data are processed for other purposes than purposes necessary for the performance of our services or for compliance with a legal obligation. Data subjects may also object any further processing of personal data after prior given consent. If data subject objects to the further processing of personal data, this may lead to fewer possibilities to use our services.

Data subjects have the right to prohibit us from using data subject's personal data for direct marketing purposes, market research and profiling by contacting us on the addresses indicated above.

Right to restriction of processing

Data subject may request us to restrict certain processing of personal data, this may however lead to fewer possibilities to use our website and services.

Right to data portability

Data subjects have the right to receive personal data from us in a structured, commonly used format.

How to use the rights

These rights may be used by sending a letter or e-mail to us on the addresses set out above, including the following information: name, address, phone number and a copy of a valid ID. We may request the provision of additional information necessary to confirm the identity of the data subject. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. In case data subject considers our processing activities of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

INFORMATION SECURITY

We will take all reasonable, appropriate security measures to protect Emooter and our customers from unauthorised access to or unauthorised alteration, disclosure or destruction of personal data we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should despite of the security measures, a security breach occur that is likely to have negative effects to privacy, we will inform the relevant Users, data subjects and customers about the breach as soon as reasonably possible.

APPLICABILITY AND CHANGES

This Privacy Policy applies to all services offered by Emooter. This Privacy Policy is published in English. Our Privacy Policy may change from time to time. The current version can be found on our website www.emooter.com/privacy. We will not make substantial changes to this Privacy Policy or reduce the rights of data subject under this Privacy Policy without providing a notice thereof.