With this Privacy Policy we provide you information on why and how we process your personal data in connection to our business operations. Please note that we also act as a processor for the personal data our customers disclose to us when they use our service. When we process personal data on behalf of our customers as their processor, we apply the practices that are described in our Data Processing Agreement (found in: https://www.zentreasury.com/data-processing-agreement) or each relevant data processing agreement.

1) WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

The controller of your personal data is ZenTreasury Oy (business ID: 2762104-2), and we are located at Heino Kasken katu 4 B 33, 00180 Helsinki, Finland. You can reach us via email at: info@zentreasury.com or phone +358 9 424 68300.

2) WHAT DEFINITIONS ARE USED IN THIS PRIVACY POLICY?

Controller means a party that is in charge of the personal data processing activities. Data subject is a term for a human being in accordance with data protection laws. Legal basis for processing means the legal basis with which the controller processes personal data of a data subject. Article 6 of the GDPR contains provisions on legal basis for processing. Personal data means any data concerning a data subject or data with which a data subject can be identified with. Privacy Policy means a data protection document that has been drafted according to Articles 13 and 14 of the GDPR, and with which the controller may inform its data subjects of the ways their personal data is processed. Processor means a party that processes personal data for and on behalf of the controller. Purpose for processing means the reason why the controller processes personal data of a data subject.

3) WHY DO WE PROCESS YOUR PERSONAL DATA?

We process personal data when we provide our services. We also process personal data for our general business purposes such as communications, marketing, development of our services, business partner relations and compliance with legal obligations. Our legal basis for processing personal data depends on the purpose for which we process personal data. We use as a legal basis (i) our contractual obligations when we carry out our contractual obligations and rights, (ii) our legitimate interests in communications, marketing, development of our services and (iii) our legal obligations when complying with our legal obligations (e.g. accounting). We process the personal data of potential customers, representatives of our customers, affiliates and potential affiliates, jobseekers, persons who contact us, business partners and other applicable data subjects. This includes e.g. processing of names, basic contact information, customer and affiliate relationship data, working related data (e.g. job role, CV and expertise), and IP addresses.

4) FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data from you, digital services (e.g. email service providers), our affiliates, authorities and public sources (e.g. official registries such as trade registry).

5) DO WE TRANSFER YOUR PERSONAL DATA?

As a general rule, we will not disclose your personal data to third parties. However, if we are required by mandatory law or governmental authorities to disclose your personal data, we will assess the legality of such disclosure on a case-by-case basis. We do share, i.e. transfer your personal data to others as part of our normal business activities when using various digital services. For example, we use the following digital services provided by data processors, which involve the processing of personal data: data storage services (e.g. cloud services), communication services (e.g. e-mails) and financial management tools.

6) DO WE PROCESS YOUR PERSONAL DATA OUTSIDE THE EU AND THE EEA AREA?

Your personal data may be processed outside the EU and the EEA area. In these situations, we ensure an adequate level of data protection, for example, through standard contractual clauses, adequacy decisions, Data Privacy Framework (DPF) and other similar arrangements.

7) HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We retain personal data for (i) as long as we have a valid contractual relationship in connection to data, (ii) as long as it is necessary to fulfil the purpose of data processing and/or (iii) for as long as we have a legal obligation to retain data.

8) WHAT DATA PROTECTION RIGHTS DO YOU HAVE?

You may have the right to use the below listed data protection rights under the GDPR:

Right to inspect (art. 15)
Right to rectify (art. 16)
Right to erasure (art. 17)
Right to restriction of processing (art. 18)
Right to data portability (art. 20)
Right to object; especially when processing personal data based on legitimate interests (art. 21)
Right not to be subject to automated individual decision-making, including profiling (art. 22)

If you would like to use your rights or inquire something about data protection, please be in touch via email (see contact information from Section 1). You may also have a right to lodge a complaint with the data protection authorities, if you think that the processing of your personal data infringes data protection laws.

9) CAN THIS PRIVACY POLICY BE AMENDED?

We may unilaterally amend this Privacy Policy. We update the Privacy Policy as necessary, for example, when there is a change in legislation. Amendments to this Privacy Policy will take effect immediately when we post an updated version on our website. If we make significant changes to the Privacy Policy, or if there is a significant change in the way it is used, we will notify the data subjects.