As regards the materials, communication and content Users insert into the Service, Media Tailor processes this personal data as a data processor and the relevant customer organization shall be considered to be the data controller with regard to this personal data.
CONTROLLER’S CONTACT DETAILS
Name: Media Tailor Oy
Company ID: 2682288-9
Mail address: Uutiskatu 2, 00240 Helsinki
Contact: Markus Paul
PERSONAL DATA PROCESSED AND SOURCES OF DATA
We collect two types of information concerning the Users: (i) User Data; and (ii) Analytics Data. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data.
Media Tailor may process the following User Data:
- name and user name;
- organisation and work title;
- profile picture;
- contact details such as email address and phone number;
- any direct correspondence with Media Tailor, such as support requests;
- social media plug-ins integrated to the Service;
- direct marketing opt-outs and opt-ins.
Most of the User Data is received directly from Users at the point of registration or in connection with the use of the Service.
Analytics Data we gather in connection with the use of our Service includes for example the following data:
- IP address;
- device and device identification number;
- operating system;
- time of visit;
- browser type and version;
- language settings.
We use various technologies to collect and store Analytics Data and other information when Users visit our Service, including cookies.
PURPOSES AND LEGITIMATE GROUNDS OF PROCESSING
Personal data is processed by Media Tailor for the following purposes:
To provide our Service and carry out our contractual obligations
We process personal data to be able to offer the Service to our Users and to run and maintain our business. Personal data may be processed in order to carry out our contractual obligations towards the User. We may use the data for example to offer essential functionalities of the Service and to provide access to the Service. If an User contacts our customer service, we will use the provided information for answering questions and solving possible issues.
For customer communication and marketing
We may process personal data for the purpose of contacting our Users regarding our Service and for informing Users of changes in our Service. We may also process personal data to market our Service.
For quality improvement and trend analysis
We may process information regarding the use of the Service to improve the quality of our Service e.g. by analysing any trends in the use of our Service. When possible, we will do this using only aggregated, non-personally identifiable data.
We primarily process personal data based on our legitimate interest whilst fulfilling our contractual obligations towards our customers organisations. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy. In some parts of the Service, Users may be requested to grant their consent for the processing of personal data. In this event, Users may withdraw their consent at any time.
Media Tailor stores Users’ personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we, our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the User’s domicile.
We will take steps to ensure that the Users’ personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or other similar arrangements.
PERSONAL DATA RECIPIENTS
We do not share personal data with third parties outside of Media Tailor’s organization unless one of the following circumstances applies:
For legal reasons
We may share personal data with third parties outside Media Tailor’s organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Media Tailor, our Users or the public in accordance with the law. When possible, we will inform Users about such transfer and processing.
To authorized service providers
For other legitimate reasons
With explicit consent
We may share personal data with third parties outside Media Tailor’s organization for other reasons than the ones mentioned before, when we have the User’s explicit consent to do so. The User has the right to withdraw this consent at all times.
Media Tailor does not store personal data longer than is legally permitted and necessary for the purposes of providing the Service or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use. We will store User’s personal data for as long as the User is a registered user of our Service and, thereafter, for no longer than is required by law or reasonably necessary for our legitimate interests for example for claims handling, internal reporting, marketing and reconciliation purposes.
We will store Analytics Data relating to the Service no longer than reasonably necessary.
Right to access
You have the right to access your personal data processed by us. Users may contact us and we will inform what personal data we have collected and processed regarding the said User.
Right to withdraw consent
In case the processing is based on a consent granted by User, User may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Service. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
Users have the right to have incorrect or incomplete personal data we have stored about the User corrected or completed. You can correct or update some of your personal data through your user account in the Service.
Right to erasure
Users may also ask us to erase the User’s personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
Users may object to the processing of personal data if such data are processed for other purposes than purposes necessary for the performance of our Service to the User or for compliance with a legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.
Right to restriction of processing
Users may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Service.
Right to data portability
Users have the right to receive their personal data from us in a structured and commonly used format and to independently transmit those data to a third party.
How to use the rights
The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above, including the following information: the full name, company name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the User. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
Notwithstanding any consent granted beforehand for the purposes of direct marketing, User has the right to prohibit us from using User’s personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the functionalities of the Service or the unsubscribe possibility offered in connection with any direct marketing messages.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, firewalls, secure facilities and access right systems. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our Service, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of Users, we will inform the them and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
LODGING A COMPLAINT
In case User considers our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.
PERSONAL DATA PROCESSING
Appendix 2: Data Processing Agreement deals with the obligations of Service Provider and Customer regarding the processing of
personal data. The appendix is governed by the Data Protection Act in cases where Customer is a
Registrar and Service Provider is a processor.