MyFondia VirtualLawyer

Updated on 25th May 2018

Controller

Fondia Plc (primary responsible party)

PL 4

020 7205 400

fondia@fondia.com

and our group companies:

Fondia Legal Services AB

Fondia Baltic Oü

(hereafter ”We” or ”Fondia”)

Contact Person for This Register

privacy@fondia.com

Name of this Register

CUSTOMER, SUPPLIER AND MARKETING REGISTER

What are the Legal Bases for and Purpose of the Processing of Personal Data?

The bases for processing personal data are our legitimate interests (e.g. customer relationship management, invoicing), performance of a contract between us and/or a legal obligation.

We process personal data to:

We use the personal data stored in the customer register also for profiling purposes. Profiling is carried out by creating a unique customer ID or file (for example a cookie) for the data subject and storing this ID on the device of the data subject. This enables us or our subcontractor to combine the data generated by the use of different products and services, and to create a profile of the data subject’s behavior. The purpose of this profiling is to identify customer behavior to target marketing and develop our services to better meet our customers’ needs.          

What Data Do We Process?

We process the following personal data of our customers, suppliers or other data subjects (like prospects or individuals participating in our trainings) in connection with this customer, supplier and marketing register:

From Where Do We Receive Data?

We receive information primarily from the data subject him-/her-/itself, authorities, credit information companies, contact information service providers and other similar reliable sources.

For the purposes described in this privacy policy, personal data may also be collected and updated from publicly available sources such as newspapers and other news sources, professional social media networks and company websites, as well as based on information received from authorities or other third parties within the limits of the applicable laws and regulations. Data updating of this kind is performed manually or by automated means. 

To Whom Do We Disclose Data and Do We Transfer Data Outside EU or EEA?

We disclose information from this customer, supplier marketing register to our co-operation partners who do marketing and arrange campaigns and events with an on behalf of us, and who deem themselves to be data controllers instead of data processors working on our behalf (these parties include social media companies and advertisement networks). Otherwise we do not disclose the information to other parties except where legislation or an order by the authorities requires us to do so.

We both process information ourselves and use subcontractors that process personal data on behalf of and for us (a current list of our subcontractors may be found here: subcontractors). We have outsourced our IT management and the maintenance of our customer and marketing systems to outside service providers on whose servers the personal data are stored.

We transfer personal data outside EU/EEA as a part of our operations. When we transfer personal data, we will make sure that the personal data in question is protected according to the privacy legislation in force from time to time by using the EU commission model clauses or by ensuring the data importer belongs to the Privacy Shield system.

How Do We Use Cookies on Our Website?

Our website uses cookies and other similar technologies for managing and developing the website, improving and analyzing the user experience and targeting advertisements in our and our partners’ services. If you visit our website and the cookies have been enabled in your browser settings, we deem that you have consented to our use of cookies on our website.

By using cookies, Fondia may collect information about e.g. from which website the user has arrived, what pages the user is browsing and when, which web browser the user is using and the IP address of the device.

We use the information collected by the cookies typically for the following purposes:

Necessary cookies and service provision: Cookies are essentially necessary for the proper functioning of our website and they enable a good user experience. These cookies do not collect information that would enable us to identify the user.

Cookies that improve the site: By following the use of these cookies, we can improve the functioning of our website. We receive information e.g.  about which parts of our website are the most popular, to which sites users leave from our website and where they arrive from as well as how long they stay on our site. We also receive information about which articles, pages and blog posts users read most often (so that we know which topics are popular).

Social media and targeted advertisement: By using these cookies we can make the content of the website as individually customized as possible, and thereby show e.g. targeted advertisement and content based on the user’s prior behavior. Fondia uses advertisement cookies managed by third parties in order to present its products both on its own website and on the sites of third parties. You can disable some of the third party advertisement cookies from their site settings.

Our website may include links and connections to third party websites, products and services as well as so called community plug-ins of third parties (such as LinkedIn and Twitter). The third party plug-ins integrated into the Fondia website are loaded from third party servers and thus the third party may install their own cookies on the user’s device. These third party services and applications offered on the Fondia website are subject to the privacy policies or notices of such third parties. We recommend you to familiarize yourself with such third party privacy policies or notices.

You can review the available cookie settings on your web browser. If you wish so, you can change the settings for the use of cookies by changing your web browser’s settings to decline the storing of cookies on your device. In some cases, this may lead to slower browsing of websites or the access to some sites to be denied altogether. A part of the cookies on our website are managed by third parties and you may alternatively use the tools of these third parties to decline the use of these cookies.

The storage and retention period of the cookies varies by cookie type. The session cookies elapse when you close the web browser. Permanent cookies usually have a term of use, which varies from two months to a couple of years.

How Do We Protect the Data and How Long Do We Store Them?

The information is collected into databases protected by firewalls, passwords and other technical measures. The databases and the backup copies of them are in locked premises and can be accessed only by certain pre-designated persons. Each user has a personal username and password to the systems where personal data are stored.

We store the data as long as it is necessary for the purpose of processing the data. Personal data in the customer and marketing register is erased after the claim period related to a specific customer relationship or service has elapsed. This period is by default ten (10) years. Data related to marketing activities is processed until further notice.

We regularly review the need for data storage taking into account the applicable legislation. In addition, we take all reasonable actions to ensure that no incompatible, outdated or inaccurate personal data are stored in the register taking into account the purpose of the processing. We correct or erase such data without delay.

What Are Your Rights as a Data Subject?

As a data subject you have the right to access the personal data stored in this register concerning yourself, and the right to require rectification or erasure of that data. You also have the right to withdraw your consent where we process your data based on consent.

As a data subject, you have the right, according to EU’s General Data Protection Regulation (applied from 25.5.2018), to object to processingor to request restricting the processing, and to lodge a complaint with a supervisory authority.

For specific personal reasons, you also have a right to object profiling and other processing concerning you, when processing the data is based on our legitimate interest. In connection to your claim, you should identify the specific situation on which you object the processing. We can refuse to act on such request on the basis of the law.

As a data subject you have the right to object to processing, including profiling, at any time free of charge in so far as it relates to direct marketing.

All requests and requirements concerning this section should be submitted in writing to the address mentioned above in section "Contact Person for This Register".

Changes in this Privacy Policy

Should we make amendments to this privacy policy, we will place the amended policy on our website, with an indication of the amendment date. If the amendments are significant, we may also inform you about this by other means, for example by sending an email or placing a bulletin on our homepage. We recommend that you review this privacy policy from time to time to ensure you are aware of any amendments made.