ZenTreasury OY'S PRIVACY POLICY AS A CONTROLLER

Last Modified: November 23, 2018

This ZenTreasury Oy’s (hereinafter ZenTreasury Oy may also be referred to as “we” or “us”) privacy policy describes our personal data processing activities as a controller (hereinafter “Privacy Policy”) for the categories of data subjects described in Section 3 below (hereinafter our data subjects may also be referred to as “you”).

This Privacy Policy contains our records of processing activities as the controller and is also a privacy notice from us to you of the ways we process your personal data. Thus, this Privacy Policy covers at least the information required in Articles 13, 14 and 30 of the EU’s General Data Protection Regulation (679/2016) (hereinafter “GDPR”).

NB! We also act as a processor for the personal data our customers disclose to us when they use our SaaS services. When we process personal data on behalf of our customers, we apply the practices that are described in Sections 14 and 15 below. In addition, we comply with the provisions of our Data Processing Agreement (found in: https://www.zentreasury.com/data-processing-agreement) or each relevant data processing agreement.

We may make changes to this Privacy Policy.

1) CONTROLLER

Name: ZenTreasury Oy

Business ID: 2762104-2

Address: Aalto Start-Up Center Otakaari 5, 02150 Espoo, Finland

2) CONTACT PERSON

Name: Lars Nevalainen

Contact details: +358942468301, [email protected]

3) DATA SUBJECTS AND PERSONAL DATA

4) PURPOSE FOR PROCESSING

5) LEGAL BASIS FOR PROCESSING

Customers and potential customers:
  • contact details; and
  • customer relationship data.
Management and development of customer relationships Contract
  • to perform the contracts to which we are a party to
Marketing Our legitimate interest
  • to manage and develop our customer relationships and further develop our business operations
NB! You have a right to opt-out of direct marketing each time we provide marketing to you.
Affiliates and potential affiliates:
  • contact details; and
  • affiliate relationship data.
Management and development of affiliate relationships Contract
  • to perform the contracts to which we are a party to
Marketing Our legitimate interest
  • to manage and develop our affiliate relationships and further develop our business operations
NB! You have a right to opt-out of direct marketing each time we provide marketing to you.
Jobseekers:
  • contact details;
  • CV;
  • possible registration data; and
  • possible other data the data subject chooses to disclose to us
Management of job applications and jobseeker relationships Our legitimate interest
  • to manage our jobseekers and possibly employ them
NB! You have a right forbid us from processing your personal data.
Compliance with legal obligations Legal obligations
  • to comply with several legal obligations as an employer
Persons who contact us, including social media contacts (e.g. persons who like our Facebook-page)
  • contact details; and
  • possible other data the data subject chooses to disclose to us
Management of contacts Our legitimate interest
  • to manage contacts made to us
NB! You have a right forbid us from processing your personal data.

6) REGULAR SOURCES OF INFORMATION

Data regarding the data subject are regularly gathered:

  • from data subjects;

  • by ZenTreasury Oy’s other affiliate companies; and

  • from the public sources such as websites, Population Register Center/Population Information System, Posti’s address database, phone companies’ databases and other similar private and public registries.

7) PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

Data subjects Retention period
7.1) Customers Necessary data shall be retained for a period of three (3) years following the end of customer relationship.
7.2) Potential customers Necessary data shall be retained for a period of three (3) years following collection of the data, if the data subject has not turned into our actual customers.
7.3) Affiliates Necessary data shall be retained for a period of three (3) years following the end of affiliate relationship.
7.4) Potential affiliates Necessary data shall be retained for a period of three (3) years following the first contact made, if the potential affiliate has not turned into our actual affiliate.
7.5) Jobseekers Necessary data shall be retained for a period of twelve (12) months following the first contact made, if the jobseeker has not turned into our employee.
7.6) Persons who contact us (not including social media) Necessary data shall be retained for a period of three (3) years following the contact.
7.7) Social media contacts Necessary data shall be retained for as long as the data subject deletes his/her data.

7.8) However, we may retain only the necessary data of the data subjects for longer than is described above, where we are required to do so by law, it is necessary due to legal proceedings and it is necessary for any similar reason. We shall be careful not to apply this Section in vain.

7.9) We inspect the necessity of the personal data stored regularly and keep records of the inspections.

8) CATEGORIES OF RECIPIENTS OF PERSONAL DATA

The recipients of personal data may consist of:

  • ZenTreasury Oy’s affiliates;

  • parties who offer data storage services;

  • parties who offer accounting and auditing services;

  • parties who help ZenTreasury Oy to fulfill its legal obligations; and

  • ZenTreasury Oy’s customers.

9) INFORMATION TRANSFER OUTSIDE OF EU OR THE EUROPEAN ECONOMIC AREA

We can transfer data outside the EU /EEA. When doing so, we ensure adequate safeguards for the data.

10) DATA SUBJECTS’ RIGHTS

The data subject has a right to use all of the below mentioned rights.

The contacts concerning the rights shall be submitted to the contact details stated in Section 2. The rights of the data subject can be put into action only when the data subject has been satisfactorily identified.

Right Description
10.1) Right to inspect Having presented the adequate and necessary information, the data subject has the right to know what, if any, data the controller has stored of her/him. While providing the requested information to the data subject, the controller must also inform the data subject of the controller’s regular sources of information, to what are the personal data used for and where is it regularly disclosed to.
10.2) Right to rectify and erasure The data subject has a right to request the controller to rectify the inaccurate and incomplete personal data concerning the data subject. The data subject can request the controller to erase the personal data concerning the data subject, if:
  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • the data subject withdraws consent on which the processing is based on;
  • the personal data have been unlawfully processed; or
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
Let it be known that the data subjects’ rights to rectify and erase data does not concern the data which the controller must retain due to its legal obligations. If the controller does not accept the data subject’s request to rectify or erase the personal data, it must give a decision of the matter to the data subject in a written form. The decision must include the reasons for which the request was not granted. The data subject may refer the matter to the relevant authorities (the Data Protection Ombudsman in Finland). The controller must inform the party to whom the controller has disclosed the personal data to or has received the personal data from of the rectification or erasure of personal data. However, there is no such obligation where the fulfilment of the obligation would be practically impossible or otherwise unreasonable.
10.3) Right to restriction of processing The data subject can request the controller to restrict the processing of the personal data concerning the data subject where one of the following applies:
  • the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; or
  • the data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If the controller has based the restriction of the processing of personal data on the abovementioned criteria, the controller shall give a notification for the data subject before removing the restriction.
10.4) Right to data portability The data subject shall have the right to receive the personal data concerning her/him, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or a contract.
10.5) Right to object Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning her/him for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where personal data are processed on the basis of our legitimate interests, the data subject shall have the right to object the processing of personal data concerning her/him for such purposes.
10.6) Automated individual decision-making, including profiling The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. However, the data subject shall not have the aforementioned right if the decision is:
  • necessary for entering into, or performance of, a contract between the data subject and us;
  • is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
  • is based on the data subject's explicit consent.
10.7) Right to withdraw consent Where the legal basis for the processing of personal data is the consent of the data subject, the data subject shall have the right to withdraw her/his consent.

11) RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

Data subject shall have the right to lodge a complaint with a supervisory authority, if the data subject considers that the processing of personal data relating to him or her infringes the GDPR. The complaint can be lodged in the Member State of her/his habitual residence, place of work or place of the alleged infringement.

12) COOKIES

Our service uses cookies which are used in order to make it more user-friendly and track your use of the Service: we gather, measure and analyze data concerning your use of the service including, but not limited to, activity, page views, unique visitors and bounce rate. This is a standard policy regarding most websites.

Cookies are small text files that a website stores on your device when you browse that website. Cookies store data of your website use. We do not use cookies for identifying a person.

You can control and/or remove cookies freely at the individual browser level. Instructions can be found for example in here: aboutcookies.org

We use the following third party cookies:

Cookie name Provider Purpose
__cfduid hs-analytics.net Used by the content network, Cloudflare, to identify trusted web traffic.
__cfduid hs-scripts.com Used by the content network, Cloudflare, to identify trusted web traffic.
__cfduid hscollectedforms.net Used by the content network, Cloudflare, to identify trusted web traffic.
__cfduid hubspot.com Used by the content network, Cloudflare, to identify trusted web traffic.
__cfduid zentreasury.com Used by the content network, Cloudflare, to identify trusted web traffic.
__hs_opt_out hubspot.com This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies.
__hssc hubspot.com This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
__hssrc hubspot.com Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
__hstc hubspot.com The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).
_ga zentreasury.com Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
_gat zentreasury.com Used by Google Analytics to throttle request rate.
_gid zentreasury.com Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
hubspotutk hubspot.com This cookie is used to keep track of a visitor's identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts.
lang cdn.syndication.twimg.com Remembers the user's selected language version of a website.

13) SECURITY OF PROCESSING

We carry out the appropriate measures (including physical, digital and administrative measures) to protect personal data against loss, destruction, misuse and unauthorised access or disclosure). For example, personal data can only be accessed by the people who need it to carry out their work.

14) DATA PROTECTION PRINCIPLES

ZenTreasury Oy uses all reasonable efforts to maintain physical, electronic, and administrative safeguards to protect personal information from unauthorized or inappropriate access, but ZenTreasury Oy note that the Internet is not always a secure medium. ZenTreasury Oy restricts access to information about data subjects only to the personnel of ZenTreasury Oy that need to know the information e.g. for responding to inquiries or requests made by the data subjects.