Privacy Statement

Privacy Statement

1. Introduction

In this privacy statement we explain how we collect and process personal data when providing services (including, but not limited to, the following website www.comreal.fi, and all related discussion forums, directories and databases, as well as the services provided by Comreal Oy) (“Service”).

We are committed to protecting the privacy of the users of the Services in accordance with applicable legislation.

2. Purposes of processing and legal basis

Purposes of processing personal data

We collect and process personal data so that:

• the user can be registered for certain services on our website;
• the user can use certain services on our website;
• our or selected third parties’ services can be marketed to the user in accordance with the user’s consent;
• we can improve the user’s experience of the Service by collecting website usage data using cookies and other analytics techniques;
• our website can be administered.

Legal basis for processing personal data

We collect and process personal data in order to fulfil our obligations arising from contracts and to comply with our obligations arising from legislation. In addition, we process personal data on the basis of legitimate interest in order to maintain and develop our business and services.

3. What personal data do we collect?

We collect from the users of our service the personal data that is necessary for the purposes of use defined in this privacy statement:

a) Information you provide to Comreal Oy

• Contact and registration information
• Demographic information, such as age and gender
• Information related to the contractual relationship, such as descriptive information on products or services, invoicing and payment information, customer feedback and contacts
• Recorded customer calls
• Profiling and interest information provided by the user
• Permissions and consents
• Any other information provided by the user that we need for the purposes defined in the privacy statement

b) Information possibly collected from public registers

c) Information observed from the use of the Services

Cookies and other analytics technologies are used to observe the use of the Services. The use of cookies is common and many websites utilize them. A cookie is a small data storage program that the computer’s browser installs on the user’s hard drive. Whenever the user’s browser retrieves the site from the Company’s server, a message is sent back to the user’s computer. The message sent speeds up the site and simplifies logging in, stores the user’s usage data and targets the site to the user.

Cookies and other possible analytics technologies are used to collect, for example, the following information:

• Usage and browsing data of the features of the Service, such as the advertisements that have been displayed and information about clicks on advertisements
• The page from which the user has arrived at our site, device model, unique device and/or cookie identifier, data collection channel, browser version, IP address, session identifier, session time and duration, as well as screen resolution and operating system
• Location data, if the user has given explicit permission for this
• Other information collected with the user’s consent

d) Information derived from the use of the Services

Derived information is inferred through analytics from the observed use of the Service and/or from information provided by the customer themselves, for example the user’s possible interests or segmentation into a certain group of users.

All the information we collect may be used to target the Service to the user. We use cookies to track information that the cookie of our site has installed on the user’s computer. In the menu of most browsers there is a Help menu item that tells how to block the acceptance of cookies, how the browser notifies about receiving cookies and how cookies can be turned off. If cookies are turned off, use of the site may be limited or prevented.

4. How long is users’ data stored?

We store users’ personal data only for as long as it is needed for the purpose for which it was collected, or for the maximum period permitted by law. The length of the retention period for personal data therefore varies depending on the data. This also means that we may retain your personal data even if your contractual relationship with us has ended, but only for as long as we have a reason to do so.

5. Transfer of personal data in order to provide the Comreal Oy service

We transfer personal data only to the extent that third parties need access to the personal data we process in order to provide the Service for the purposes defined in this privacy statement.

Third-party marketing and advertising

We do not share users’ personal or identifying information with marketing or advertising parties. In order to target communications or marketing correctly, we may transfer to third parties anonymised demographic data, interests or, for example, location-based targeting values.

Your consent

If the user has given their consent, we may share the user’s information with selected third parties so that they can contact the user.

Scientific research

We may disclose data for scientific or historical research, provided that the data has been converted into a form in which the data subject can no longer be identified from it.

For legal reasons

Your personal data may be disclosed in accordance with requirements presented by a competent authority and conditions based on law. If we sell, buy, merge or otherwise reorganize our business, users’ personal data may be disclosed to buyers and their advisors.

6. International data transfers

Comreal Oy aims to provide its services and process personal data using operators and services located in the EU or EEA.

Some of our subcontractors, distributors and partners are located outside the European Economic Area. In such cases your personal data may be transferred between countries. Such transfers may include disclosures of personal data outside the EU or EEA to countries whose legislation on the processing of personal data differs from the requirements of Finnish law. In such cases Comreal Oy ensures an adequate level of protection of personal data, for example by agreeing on the matter with the processor of personal data using model contract clauses or other means for transferring personal data to third countries in accordance with data protection legislation.

7. Protection of personal data

Comreal Oy uses up-to-date practices to protect personal data. This means that we use physical, administrative and technical safeguards to reduce the risk of loss of personal data and to reduce misuse as well as unauthorized use, disclosure or modification. We store your personal data on secure servers, so that only authorized persons can access the data on these servers. Comreal Oy may also protect users’ personal data by utilizing Secure Sockets Layer (“SSL”) or other similar encryption software.

8. Third-party websites

This privacy statement applies only to our Services and we are not responsible for the privacy practices of other websites. We recommend that the user check the privacy statements of the websites they use.

9. Changes to the privacy statement

We may change this privacy statement. The amended privacy statement is available on the Company’s website so that users are always aware of how their personal data is processed.

10. Your rights

Right of access

You have the right to check what data concerning you has been stored in the register. We will provide the data in the form required by law.

Right to request rectification of data

You have the right to request the correction or completion of incorrect, inaccurate, incomplete, outdated or unnecessary data.

Right to request erasure of data

You can ask us to delete your personal data from our systems. We will carry out the measures you request unless we have a legitimate reason not to delete the data. The data will not necessarily be removed immediately from all of our backup or other similar systems.

Right to restrict processing of data

You can ask us to restrict certain processing of your personal data. A request to restrict the processing of data may result in more limited possibilities to use our website and our services.

Right to object to processing of data

You can also request restrictions on the processing of your personal data if your data is processed for purposes other than performing our service or fulfilling a legal obligation. Objecting to the processing of personal data may result in more limited possibilities to use our website. You have the right to refuse electronic direct marketing by following the instructions included in all marketing messages we send.

Right to data portability

You have the right to receive your personal data from us in a structured and commonly used format so that you can transmit the data to another controller.

Right to withdraw consent

If the processing of your data is based on consent, you have the right to withdraw your consent at any time.

11. Exercising your rights

You can exercise your rights by sending a letter or an email that includes your name, address, telephone number and a copy of a valid identity document. If your request concerns personal data in a cookie, you must attach a copy of the cookie in question to your request. We may ask for additional information necessary to verify your identity. We may reject requests that are repeated unreasonably often, are excessive or are unfounded.

If you consider that the processing of your personal data conflicts with applicable legislation, you can lodge a complaint with the local data protection supervisory authority.

12. Who is the controller and whom can I contact?

The controller is:

Comreal Oy

For matters concerning the register you can contact:

info@comreal.fi