Vahva Digital's Privacy Policy Statement

Your privacy is important to us. Vahva Digital Oy is committed to protecting the privacy of the users of its web services and participants of its events, customer and partner contact persons and contact persons of potential customers and partners related to sales, cooperation and contract preparation according to all applicable laws and best privacy practices. This privacy statement describes the practices concerning the collection and processing of personal data at Vahva Digital. By using Vahva Digital's websites and/or participating in Vahva Digital's events, user approves the terms of this privacy policy. If you do not accept the practices described in this privacy statement, we do not recommend that you submit your personal data to Vahva Digital.

Controller

Vahva Digital Oy
Laivasillankatu 14 B 42
00140 Helsinki, Finland
+358 45 499 7000

Questions concerning the register

Tommi.rinnemaa@vahvadigital.com
+358 45 499 7000

Name and content of the register

Vahva Digital's customer register.

The register contains e-mail addresses of Vahva Digital's newsletter subscribers and e-mail addresses, names, organization information of those users who have submitted this information to Vahva Digital while visiting Vahva Digital's websites and downloading material from Vahva Digital's websites. The register also contains details of customer and partner contact persons and contact persons of potential customers and partners related to sales, cooperation, and contract preparation.

What information do we collect and how?

The customer register may contain the following personal data that can be obtained from the data subject themselves, in connection with the preparation of the contract, from the person's employer and from public information sources, as well as from the data the user has him/herself submitted. The information we collect is:

• Name
• E-mail address
• Mobile phone number and/or other telephone number
• Company and position
• Company size
• Company industry
• User submitted information about interests and subscription preferences

In addition, we use analytics and marketing automation tools which collect users' browsing information, such as traffic sources, browser and devices used, time spent in Vahva Digital's website, pages visited, geographic location etc. Personal data is mainly collected at the point of subscription, or later during the customer relationship. Vahva Digital's websites use cookies, web beacons and other similar methods to improve user experience and to develop websites and services further and for targeting content and communications. Cookies are small pieces of data sent from a website and stored on the user's computer by the user's web browser. Cookies can be blocked from the cookie settings that are presented to users when they first land on Vahva Digital's pages, or later from the cookie setting menu (lower left corner). Our pages may also include other third-party components, such as lead trackers.

For which purposes is my data collected? What is the legal basis of processing my data?

Personal data is processed for the use of customer relationship management, data analytics, export control and sanctions screening and other similar measures concerning the legality of business transactions, Vahva Digital's marketing and/or direct marketing actions through Vahva Digital's tools according to the Personal Data Act without disclosing customer personal data to any third party. Vahva Digital maintains information about Vahva Digital's newsletter subscribers and users of its website. Newsletters are sent to subscribers by email based on customer register.

The legal basis for the collection and processing of personal data is the controller's legal obligation under the General Data Protection Regulation (2016/679, "GDPR") when Vahva Digital carries out export control and sanctions screening and other similar measures concerning the legality of business transactions.

Marketing automation

Vahva Digital websites can run a marketing automation system that is used for improving general user experience of Vahva Digital's websites and content to the visitor and creating target segments for direct marketing campaigns.

Vahva Digital places cookies when the visitor first arrives to Vahva Digital's website to learn how visitors consume content in all its digital services. Visitor's personal data remain anonymous to Vahva Digital until:

1. Visitor subscribes to Vahva Digital's material

The user's personal data may be linked to the cookie when a visitor reveals her/his person subscription to the newsletter. The given information is stored to Vahva Digital's customer register.

2. Visitor arrives at the website from an email marketing message sent by Vahva Digital

The user's personal information may be linked to the cookie when the user arrives to the website via an email marketing message sent by Vahva Digital. The source for e-mail marketing messages is Vahva Digital's customer register. A user whose cookie is linked to personal data can receive email marketing that is personalized based on her/his website visitor history. In case a user wishes to unassociated their previous browsing history, they can do so by clearing their browser cookies.

How do we store personal data and for how long?

Personal details are kept confidential. The information network and hardware, where the register is located are protected by firewall and other necessary technical measures. The register's security measures comply with the data security policy of Vahva Digital. We use appropriate physical, technical and administrative security measures to protect your personal data against misuse. We have responsible people who have been specifically appointed to take care of privacy protection and data security. The register holder will not disclose any customer personal data to any third party unless required by Finnish authorities.

We store our data primarily in the EU or the EEA. Data can be transferred outside the EU or EEA as some of the technical cloud platforms in use are located in the US and there isn't yet a European instance available. In this case, we will ensure that the country to which the data is transferred to is approved as having a sufficient level of privacy protection by the European Commission, or by using standard contractual model clauses approved by the European Commission. We store user data according to the relevant legislation and for maximum of two years, or as long as is necessary for the purposes defined in this privacy statement. After the basis for processing your personal data has ended, we will delete your personal data.

As a general rule, customer and partner contact data will be stored for at least 3 years from the most recent activity to which the data subject or his/her organisation has identifiably joined. Personal data relating to the preparation, management and execution of the contract shall be processed for at least 10 years from the most recent activity and termination of the contract to which the data subject or organisation represented by the data subject has joined. If the contract has been agreed to be valid for the time being, the contact information will be stored at least for as long as the contract.

User's rights

You have the legal right to inspect the data we have collected concerning your personal information. You also have the right to request the correction or deletion of incorrect, defective, unnecessary or outdated personal data.

Information can be removed from the register based on a personal request. Requests for change in register related matters shall be submitted in writing to the postal address Vahva Digital Oy, Laivasillankatu 14 B 42, 00140 Helsinki, Finland or by e-mail to info@vahvadigital.com. Newsletter subscribers have the right to disallow Vahva Digital from sending newsletters to them. You can disallow the newsletter by unsubscribing to the newsletter or by sending a request to Vahva Digital.

Preventing the use of cookies

Users can prevent the use of cookies by changing their browser settings. Preventing cookies may impact the way our services function.

Creating a new cookie profile by clearing cookies

Users can clear their cookie history from their browser settings. By regularly deleting cookies from the browser, users can change the identifier on the basis of how a specific online user profile is generated. Clearing cookies will not completely prevent information from being collected; however, it does reset the user's online profile based on new cookies.

Changes to this privacy statement

Vahva Digital may from time to time make changes to this privacy statement without prior notice. However, if material changes are made to this privacy statement, Vahva Digital will display a notification of this at the beginning of this privacy statement. Changes may also be based on changes in legislation. We recommend that users read our Privacy Policy statement on regular basis to keep track of changes.