This document describes the processing of personal data of persons using the services offered by FREE-Laskutus Oy and its subsidiaries and partner companies (later referred to as “FREE”)
Given personal data and personal data that the data subject otherwise has submitted to FREE or FREE has obtained from publicly available sources. Any links in this web site to possibly access web sites of other third parties are operated in accordance with the privacy notices issued by the operator of such web site. The users are advised to read any such privacy notices before using the web sites of the third parties.
1. Controller and Contact Person
FREE Laskutus Oy (BIC 2768169-4), having its registered office in the address Perhonkatu 6A, 00100 Helsinki, Finland. Furthermore, Free-Talent Oy (BIC 290844-6) act also as controller for that part the company has determined the purpose and means of personal data controlling, and processes your given personal data in its business operation.
The contact person regarding issues of personal data protection on behalf of both above referred companies is Mr. Petri Jaatinen (petri@free.fi).
2. Purposes and lawfulness of processing of personal data
Personal data shall be collected and processed for the following purposes:
(1) for offering and implementing of FREE – services as well as answering to presented requests. We use personal data also in other contacts with our clients and co-operation partners.
(2) for marketing purposes to send by email, by SMS to phone or by regular letter mail (if address given by the data subject) newsletters and/or commercial offers or information of FREE services and products.
Processing may mean one or several of following operations: data collection, recording, organization, structuring, storage, adaptation, alteration, selection, use or erasure.
The processing of personal data is based on the consent of personal data processing given by the data subject when registering in the FREE service. Submitting of data is voluntary, but is a requirement in using the FREE services.
Furthermore, it is necessary to give the data marked obligatory in the contact request phase (e.g., contact details, name, date of birth and email address of the person making the request) if the user requires that his/her request shall be replied to. Depending on the requests by the user, FREE may need also additional information. Giving of such additional information is voluntary, but if additional information should not be submitted, it may be difficult or impossible for FREE to reply to requests by the user.
If the user wishes to subscribe the newsletter and/or receive commercial contacts, it is necessary to provide an email address.
Giving the user’s data via web site takes place by filling in the required user’s data in the contact form. Data information for offering services or entering into a contract can also be given over phone, in a meeting or by email.
If the user has given his/her consent to process personal data also for marketing purposes, the data in question may be processed also for preparing statistical, opinion and market surveys relating to FREE services.
In addition to the above, in acquiring new clients FREE, in order to obtain personal data, can utilize publicly accessible sources. In such a case the categories of personal data are name, phone number and email address, and as lawful basis the legitime interests of the controller (Article 6 point f). FREE considers that it is its legitime interest to utilize personal data accessible from public sources in its business and in order to maintain competitive in its operational environment.
3. The recipients of the personal data
The personal data submitted by the user in relation to the above indicated web sites are automatically stored in the data system maintained by FREE. The data provided by phone, in a meeting or by email shall be stored in the FREE’s data system by a designated employee. In order to implement the purposes indicated above, the personal data shall be processed by the FREE’s administrative and commercial personnel as well as the enterprises including their personnel that provide data processing or other services to FREE (e.g., parties providing electronic marketing, maintenance and management services of web sites). FREE has entered into a contract with third party processors as required in the General Data protection Regulation by the EU. Additionally, FREE can transfer data to its commercial partners in case the service used by or implementation of the contract made with the client requires. Furthermore, FREE can submit personal data to authorities, financial institutions, and insurance companies that all are bound by legitime non-disclosure obligation.
The obtained and processable data will not be transferred to any third partied, except as described above, unless the data will be non-identifiable or when the data submittance is based on law or by authorities’ orders. In addition to this the data can be processed and they can be transferred in connection of corporate transactions (such as acquisition of business operations, a merger, or a division).
The personal data is stored fully confidential, protected by passwords and proportionate technical measures in the server of FREE or its service provider. The personal data is processed confidentially and only by thos employees who have been designated to do so and have committed to comply with the non-disclosure obligations and the procedures relating to data protection as required by FREE.
A part of the so-called cloud-services used by us are located outside the EEA area. When giving one’s consent to processing of the personal data (e.g., in connection with using our services) the data subject gives an express consent for the personal data to be processed by the following companies operating in the USA:
- Hubspot, Inc – Cambridge, Massachusetts, USA – https://legal.hubspot.com/privacy-policy
- Google LLC (used services – Analytics, Google Workspace, YouTube) : Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA: https://policies.google.com/privacy?hl=en_US
- Facebook Inc (used services – Facebook, Instagram, WhatsApp) – Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA: https://www.facebook.com/about/privacy/previous
- LinkedIn Corporation (a part of Microsoft): Sunnyvale, California, United States: https://www.linkedin.com/legal/privacy-policy
- Asana, Inc – 1550 Bryant Street, Suite 200, San Francisco, CA 94103, https://asana.com/terms
- Twilio, Inc (used services – Twilio, Sendgrid) – San Francisco, California – https://www.twilio.com/legal/tos
- Cloudtalk – Slovakia, Západný rad 31, 811 04 Bratislava – https://www.cloudtalk.io/terms-and-conditions
- Zoom Video Communications, Inc. – 55 Almaden Blvd, Suite 600 San Jose, CA 95113 – https://zoom.us/privacy
- ByteDance Ltd. (TikTok) – https://www.tiktok.com/legal/privacy-policy?lang=en – 5800 Bristol Parkway in Culver City, Los Angeles
- Yodiz – app.yodiz.com
- Miro – https://miro.com/legal/terms-of-service/ – 201 Spear Street, Suite 1100, San Francisco, CA 94105
- Clarity: Microsoft Corporation One Microsoft Way Redmond, WA 98052-6399 USA
- GCloud (used services- App engine, Kubernetes engine, Storage, Database): Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA https://cloud.google.com/terms/cloud-privacy-notice – Data is stored at Hamina, Finland and Belgium
- Cloud City Oy – https://my.cloudcity.fi/privacy/ – Tähdenlennonkuja 1, 02240 Espoo, Finland
- AWS – Seattle, Washington, United States – https://aws.amazon.com/service-terms/ – Data is stored at Europe (Ireland)
When giving one’s consent the data subject is aware that transfer outside the EEA area may bring risks for the data subject due to lacking the EU regulation regarding data protection level and appropriate protection measures.
4. About data protection
FREE processes your given personal data with appropriate and accurate technical and organisational protection measures. FREE’s purpose is to minimize any hazards arising from data destruction, loss, unlawful processing, access to, or processing deviating from the indicated purposes. The user shall, however, be aware of that among others there are always data protection risks in the use of Internet, and it will not be possible to secure complete data protection.
5. Additional information/about rights of the data subjects
The storage period of the personal data of persons registered (data subjects) in the FREE service is determined according to the purpose of use. In case submitting of data via web site results in a contractual relationship with FREE and in use of FREE’s services, the from time to time valid legislation (such as the Finnish Accounting Act) shall be applied regarding the storage of personal data.
The data subject has a right to ask for access to his/her personal data and right to require rectification, erasure, restriction of processing of the personal data, to object processing, and shall have a right to have the data transferred to another system by sending an email including such a request to the below specified email address.
The data subject has a right to cancel his/her consent for processing of the personal data, but this will not affect the lawfulness of the processing carried out prior to the cancellation of the consent. The data subject can also separately object the use of the personal data in direct marketing which will not otherwise affect the use of FREE’s services.
The data subject has also a right to lodge a complaint regarding processing with a supervisory authority that in Finland is the Data Protection Ombudsman (Office of the Data Protection Ombudsman, Lintulahdenkuja 4, 00530 Helsinki, Finland, or tietosuoja@om.fi).
Giving of personal data is not based on a statutory requirement. Giving the data requested in the FREE’s system/service is, however, required in order to be able to enter into a contract with FREE and to use the service. The given data can also be used in automated processing and decision-making, such as profiling. The data subject has possibility at any time to object the use of his/her personal data in automated decision-making.
In order to exercise your rights listed above you can contact us by writing to the address petri@free.fi.
6. Data regarding the use of Internet – Cookies
Data regarding the use of Internet
The data systems and programs used for operating the web site collect some amount of certain personal data, transmitting of which is a part of the Internet data transfer protocols. Such are inter alia the IP or domain addresses of the computers used by the web site visitors, and the URI (Uniform Resource Identifier) addresses of the requested resources. In addition, the data systems and programs can collect data in the server about request times, request methods, size of the received files, number codes of the server response status (ready, failure, etc.), as well as other parameters that are related to the user’s operating system and network.
These data are not collected of used in identifying of the user, but due to their nature identification of the user can be possible through processing and combining these data with data controlled by third parties.
FREE uses these data only for anonymous statistical purposes relating to the use of the web site and in order to secure appropriate functionality of the web site.
The referred data can also be used to clarify data protection breaches or other criminal acts relating to the web site. In any other cases than those of clarifying criminal acts, the data regarding web site contacts will be erased promptly after processing or within seven days at the latest.
Cookies
In some cases, FREE collects personal data using various technical mechanisms, including cookies. Cookies are created from data sent by the web site to the browser (which can be your own browser). This data can be stored on the computer (which can be your own computer) with identifiers enabling the identification of the computer, but not the user.
We may utilize cookies in further development of our services and our web site, in analyzing the use of the web site, as well as in targeting and optimizing our marketing. The purpose is to enable the web site’s function, improve its’ usability/accessibility, and statistically study the browsing usage of the web site.
You can accept or forbid the use of cookies through the settings of your web browser. Most of the web browsers accept the cookies automatically. Please note that forbidding the cookies may limit the functionality of our web site.
7. Finally
The English language translation of this Privacy Notice is a part of FREE customer service and for convenience only. Should there be any discrepancies between the Finnish language version and the English version, the Finnish version shall prevail.
