Ääni Company Ltd newsletter emailing list and www.aanicompany.com, www.sanelius.fi
Version 1.01, 20 March 2019, translation of the Finnish original available upon request.
Personal data processing
Ääni Company collects email addresses. The email addresses are considered personal data. Personal data is processed to take care of and to analyze customer relationships, to produce and personalize services, to develop business and related plans, as well as marketing, surveys and customer communications that may also be targeted and personalized.
The internet page host Weebly collects and stores visitor data by its own or other tools of their choice. Weebly states they also comply with EU General Data Protection Regulation. Ääni Company does not receive identifiable or otherwise uniquely defined user data, with the exception of the email addresses that users actively give in order to be contacted or to be included in the newsletter emailing list. The email addresses are to be used for direct marketing and other communications.
Internet pages at www.aanicompany.com collect visitor data with Google Analytics tools. This data may be used for targeted marketing communications. Ääni Company requests Google to anonymize the user’s IP address. Ääni Company does not intend to or have the ability to identify an individual use from the Google Analytics data. Data collection by Google Analytics can be retrieved from www.google.fi/policies/privacy/partners/. There you may learn, among other things, that google may also collect personal data and other uniquely identifiable data about the users.
Personal Data Collected
The only personal data collected by Ääni Company are the email addresses of the users who actively give those with their consent.
Other data, such as that collected by Google Analytics are requested by Ääni Company to be kept anonymous. Ääni Company can not identify individual users from the Google Analytics data.
Personal data (email addresses) are collected from the users themselves on the web pages, from the services they use as well as various marketing activities such as lotteries, events, competitions.
Data may be transferred to Ääni Company direct marketing register, however always in compliance with the EU GDPR.
Data may be processed by partners delivering marketing services, such as email marketing or companies providing IT systems to store and process the data.
Data Transfer outside the EU or EEA
Data may be transferred outside the EU to Weebly, Inc. or MailChimp newsletter software servers in the U.S., under and in accordance with the EU-U.S. Privacy Shield certification.
Google may process the visitor information on servers residing in the United States under and in accordance with the EU-U.S. Privacy Shield certification. In accordance with Ääni Company’s understanding, these data are anonymized and thus not personal data.
The internet page service provider Weebly transfers and processes web page visitor information in the U.S., under and in accordance with the EU-U.S. Privacy Shield certification. Further information can be found at: https://www.weebly.com/privacy. A quote: “Weebly is committed to subjecting all personal data received from European Union (“EU”) member countries and Switzerland, respectively, in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
Weebly is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and may subsequently transfer data to a third party acting as an agent on its behalf. Weebly complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Weebly is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.”
Responsibilities of external parties
Personal data (email addresses) are processed by Weebly on their own servers that reside in the United States of America. Data are protected by passwords and other technical measures. Ääni Company does not have control over any other data collected by Weebly of the users and Weebly shall be responsible for the data they collect as well as its compliance with the EU GDPR and other laws.
Google processes the user data by its own privacy policies: https://www.google.fi/policies/privacy/.
If the customer has agreed to receive marketing communications, personal data is stored until the customer cancels their consent or until Ääni Company does no longer see a need for the data.
Informing about the dataOur web pages include a form where the user opts in and understands that his or her personal data (email address) is added to the mailing list. The opt in signals the consent of the users to receive marketing communications.
Data protection and security
Data is collected into databases that are protected by firewalls, passwords and other technical measures. Passwords are regularly changed. The personal data (email addresses) can only be accessed by Weebly, Ääni Company and specifically assigned persons. In Ääni Company only assigned persons do have the right to process and maintain the register. They are bound by a non-disclosure agreement.
A person’s right to personal data
On the web pages, a request for personal data can be sent via email to Ääni Company (info at aanicompany.com).
The personal data (email address) are delivered to the email address given, provided that it matches the email address of the sender. Changes to the data, such as erasure of the data are processed through email.
Information about possible personal data breach
In the case of a personal data breach, Ääni Company will inform in due course the supervisory data protection authority and the customers affected through email.