Last updated: August 2, 2023

Kohtas Co. Finland Oy ("Kohtas" or "we") understands that your privacy is important to you. Kohtas is committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person. This Privacy Policy describes how Kohtas handles and protects your personal data in connection with Kohtas' business activities and on websites, applications, and communications that post a link to this Privacy Policy (collectively, "Websites"), in our capacity as data controllers. Please see our Website Terms of Use for more information about the terms and conditions of the use of Kohtas' Website.

INFORMATION SECURITY

Kohtas attaches great importance to your right to privacy and takes the security of your personal information very seriously. We want you to feel secure that when you deal with Kohtas, your personal data are in good hands. The information is stored in a secure location and all connections accessing or modifying the information is secured with SSL connection. The information can be accessed only by authorized and authenticated users, who have the obligation of confidentiality. You are, however, aware and understand that you are fully liable for your own actions, including but not limited to the security measures related to your devices and connections. You are also responsible for any personal information you submit in using Kohtas' services. You are responsible for studying applicable third parties' privacy policies. We advise you to study such policies carefully.

COLLECTION AND SOURCES OF PERSONAL DATA

Kohtas may collect following data related to personal information of users using Kohtas' Website or services:

• Name
• Birthdate
• Company's legal name
• Address
• Email address
• Phone number
• IP address and other log information such as device information, browser information, cookie information, date / time of access
• Business ID, Tax ID and billing or financial account information
• Government-issued identification number
• Title
• Subscription related information such as subscription type, subscription's start and end dates
• Newsletter subscription (on/off)
• Consents

Most of the personal data that we collect is provided actively by the users themselves. Users may share information with us that we store on their behalf and use to enhance their experiences. Users' device information and similar information is collected passively while user using our services.

In addition, Kohtas may obtain additional information about you from third parties such as marketers, partners, researchers, and others. This includes demographic, professional and other information that is publicly available online, including information you choose to make public through social media platforms and other public online forums. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide. We will always seek to confirm that the third party has provided transparent information about its use of this data, including its disclosure to third parties like Kohtas, in compliance with applicable law.

Kohtas' Website does not track you by collecting personal data about your online activities over time and across third party websites or online services.

We use Google Analytics to understand how our Websites are used and to improve, execute and govern experiences within our services. If you want to know more about how Google Analytics works or to exercise choice in regard to the data collected by it, please visit Google's privacy policy

We use Leadfeeder to understand how our Websites are used and to improve, execute and govern experiences within our services. If you want to know more about how Leadfeeder works or to exercise choice in regard to the data collected by it, please visit Leadfeeder's privacy policy

We use Pipedrive to enable the chat tool for our customer service organization for offering the possibility to book meetings and make contact requests. If you want to know more about how Pipedrive works or to exercise choice in regard to the data collected by it, please visit Pipedrive's privacy policy

We use a third party service, MailChimp, to manage and send our newsletters. If you sign up to our mailing list, your email address and any associated contact preferences will be stored by MailChimp (Intuit France SAS). Mailchimp may store data on servers located in the United States. Our contract with MailChimp requires them to provide the same safeguards and data protection rights for our users as they would have if the data was stored in the EU. More details about MailChimp's security safeguards and GDPR compliance can be found here: Mailchimp's privacy policy

We use Cookiebot to manage Website's cookies and other tracking technologies. We use cookies to personalise content and ads, and to analyse our traffic. We also share information about your use of our site with our advertising and analytics partners who may combine it with other information that you've provided to them or that they've collected from your use of their services. More details about Cookiebot's operations and privacy policy can be found here: Cookiebot's privacy policy

PROCESSING PERSONAL DATA

Kohtas may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which Kohtas is subject, basic operation of Kohtas' services and business activities, including in connection with some client services, service maintenance and technical support, responding to inquiries, collecting statistics regarding service usage, and conducting scientific and market research, for the performance of a contract to which you are party, in order to protect your vital interests, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Kohtas or a third party to whom it may be necessary to disclose information.

Kohtas may also use your information to fulfill your requests for information, personalize content that you view or receive on the websites, evaluate and improve our services, prevent fraud, enforce our website terms of use, accomplish other purposes you may initiate or request and analyze the websites' performance and functioning. Personal data may be used to inform of Kohtas' services, such as sending a newsletter or informing about email campaigns or other ways of maintaining the customer relationship.

As part of data processing the data may be used for profiling purposes and to perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of products and services that Kohtas provides.

The legal justification for processing personal data is fulfilling the contract between the parties or the legitimate interest of the controller, which is based on the relationship between the parties. The legal justification may also be the data subject consent, if the applicable legislation so requires. If you have questions about this legal basis you can contact Kohtas' Data Protection Officer.

You are not required to provide the personal information that we have requested, but, not providing the requested personal information may in many cases mean that we will not be able to provide you with our products or services or respond to your queries.

TRANSFER OF PERSONAL DATA, INFORMATION AVAILABILITY

Personal data may be disclosed to purposes described in this Privacy Policy in accordance with applicable data protection legislation. No information is, however, given to any third party for direct marketing purposes without an explicit permission of the user, excluding legal reasons for giving the information for authorities.

Kohtas may also share information to safety, security, and legal compliance for the purposes such as to satisfy any applicable laws or regulations. Personal data may be shared or transferred, if Kohtas explores or undergoes a business transition, such as a merger, acquisition by another company, transfer of control, or sale of assets.

Personal data may be processed by authorized third parties, who process the data on behalf of Kohtas for the purposes described in this Privacy Policy (for instance, third-party service providers of technical infrastructure or services). Such service providers may use the personal data only according to the instructions from Kohtas, i.e. only for the purpose for which the data has been collected.

Personal data may be processed outside the EEA or European Union by Kohtas' third party service providers as further defined in applicable privacy policies of third parties. Kohtas shall not be liable for such policies. The transfer of personal data to third countries may be affected by an appropriate transfer agreement in accordance with template clauses currently in force at the EU Commission and/or any other personal data transfer requirements at that time or as otherwise permitted by applicable law.

DATA RETENTION

Kohtas retains personal data, as necessary, for the duration of the relevant business relationship.

Kohtas may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that Kohtas delete your personal data, Kohtas will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the "Your Rights" section of this Privacy Policy.

YOUR RIGHTS

You have the rights according to the personal data legislation applicable in Finland, including the EU General Data Protection Regulation (GDPR), to request access to the personal data that Kohtas has collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that Kohtas has collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data. Whether you make the request by electronic means and you have not requested it by any other means, the information shall be provided by electronic means.

You also have the right to receive confirmation from Kohtas as to whether or not personal data concerning you are being processed and the right to prohibit the processing of personal data for direct marketing purposes.. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law.

If processing of personal data is based on consent, you have the right to withdraw your consent. The withdrawal of consent may, however, affect the usability and functionality of the service in question. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

In certain cases, the data subject has also the right to request from the controller restriction of processing of personal data or otherwise object to processing. Furthermore, you may require the transmission of the personal data, which you have provided to the controller in a machine-readable format based on the GDPR. All requests mentioned here shall be provided to contact person of Kohtas mentioned below. Whether you find the processing of your personal data unlawful, you have the right to lodge a complaint to the authorities responsible for personal data protection.

COOKIE POLICY

Kohtas uses cookies and similar similar tracking technologies, such as web beacons, to manage, provide, protect and improve its Website and services and collect analytics about how you use them. You may refuse to accept cookies or delete cookies already stored on your computer through the settings of your web browser. If you choose to decline cookies, some parts of the service may not work as intended.

CHANGES TO THIS PRIVACY POLICY

Kohtas reserves the right to change our practices and this policy at any time. We encourage you to check this page regularly so that you know what our current practices are. This description of the personal data processing has been last updated August 2, 2023.

CONTACT US

If you have any questions about our Privacy Policy or if you would like to communicate with our Data Protection Officer, please contact us at:

Kohtas Co. Finland Oy
Legal Department
Ludviginkatu 6
00130 Helsinki, Finland
dpo@kohtas.com