Last updated on May 8th, 2018 at 21:10 hrs.

Cluetail Ltd., registered in Finland with the Finnish Trade Register in Helsinki under Business ID FI17473488, is responsible for the processing of personal data as described in this privacy statement. This privacy statement was drawn up in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679.

Contact information:

Cluetail Ltd.
Business ID: FI17473488
Web: cluetail.com
E-mail: info@cluetail.com
Telephone: +358 50 59 33 006

Personal data

Cluetail Ltd. processes personal data which we receive as you use our service, or which you submit to us. We may process the following personal data:

  • First name and surname;
  • Address;
  • Telephone number;
  • E-mail address;
  • IP-address;
  • Other personal data which you actively submit, for example, by creating a user profile, in written correspondence, or in telephone conversation;
  • Location data;
  • Data about your interactions with our website;
  • Data about your web browsing behavior across third-party websites (for example, if we take part in an advertising campaign conducted over an advertising network);
  • Internet browser and device type;
  • Bank account information.

Special and/or sensitive personal data

With our website and/or services we don’t intend to collect data about web visitors who are younger than 16 years of age unless their parents or custodians approve of them using our services. However, we are not able to check if a visitor has reached the age of 16. Therefore we recommend that parents should engage themselves with their children’s online activities, so as to prevent the collection of data about children without parental consent. Should you be convinced that we have collected personal data about a minor without permission, please, contact us via info@cluetail.com and we will remove such information.

Purposes of our personal data processing

Cluetail Ltd. processes your personal data for the following purposes:

  • To process your payment;
  • To send our newsletter and/or ad brochure;
  • To be able to call you or send you email in case this is required in order for us to render our services;
  • To inform you of changes concerning our products or services;
  • To deliver our products or services to you.

Cluetail Ltd. analyses your behavior on our website, and possibly on third-party websites, in order to improve the website and to align our product and service offering with your preferences.

Cluetail Ltd. also processes personal data when we are legally required to do so, for example, data required by tax authorities.

Grounds for our personal data processing

Cluetail Ltd. processes personal data on the following GDPR-compliant legal grounds:

  • Consent;
  • Necessity for the performance of a contract/to take pre-contractual steps;
  • Necessity for compliance with a legal obligation;
  • Necessity for a legitimate interest pursued by the controller/a third party if not overridden by the interests or fundamental rights and freedoms of the data subject.

Automated decision making

Cluetail Ltd. does not take decisions which can have (significant) consequences for individuals on the basis of automated processing. This would involve decisions made by computer programmes or systems without human involvement such as by an employee of Cluetail Ltd.

How long we keep personal data

Cluetail Ltd. keeps your personal data no longer than strictly necessary in order to achieve the goals for which they have been collected.

Cluetail Ltd. keeps the following categories of personal data for no longer than two years after the last time they were used in communication by us, in order to enable us to maintain contact with our relations and in order to be able to serve you adequately:

  • First name and surname;
  • Address;
  • Telephone number;
  • E-mail address;
  • IP-address;
  • Other personal data which you actively submit, for example, by creating a user profile, in written correspondence, or in telephone conversation;
    Location data;
  • Data about your interactions with our website;
  • Data about your web browsing behavior across third-party websites (for example, if we take part in an advertising campaign conducted over an advertising network);
  • Internet browser and device type.

In case Cluetail Ltd. has invoiced you, or you have invoiced Cluetail Ltd., your bank account, account holder and contact information may be kept as part of our financial records as long as our business operations require it, or as long as it is required by law.

Sharing of personal data with third parties

Cluetail Ltd. does not sell your data to third parties and only provides them insofar as it is necessary in order for us to deliver on the terms of our agreement, or in order to comply with legal requirements. With third parties who process your data on our behalf, we make agreements to ensure appropriate levels of data security and confidentiality. Cluetail Ltd. remains responsible for such data processing.

Cookies and similar technologies

Cluetail Ltd. uses functional, analytical, and tracking cookies. A cookie is a small text file that is stored in the browser on your computer, tablet, or smartphone when you first visit our website.

Cluetail Ltd. uses cookies with a purely technical functionality. They make the website function properly and are instrumental in storing and retrieving your preferences. These cookies are also used to optimize the website’s functioning.

Additionally, we use cookies that can record your browsing behavior, which allows us to present customized or personalized content.

At your first visit to our website, we informed you of our use of cookies, while presenting a button to let you agree and remove the cookie notification, as well as a button linking to this section of our privacy statement.

You can opt out of the use of cookies by setting your internet browser so as to no longer store them. Furthermore, you can also remove all previously stored information from your browser by adjusting your browser’s settings.

For more information about cookies, please check: https://www.howtogeek.com/241006/how-to-block-third-party-cookies-in-every-web-browser/

Viewing, adjusting, or removing data

You have the right to access, correct, or remove personal data. You also have the right to withdraw your permission for data processing or to object to the processing of your data by Cluetail Ltd. Furthermore, you have the right to data portability. This means that you can request us to send a file with the personal data that we have of you to yourself or to an organization named by you.

You can send a request to view, correct, remove or transfer your personal data, or to withdraw your permission to, or to object against, our processing of your personal data, by email to info@cluetail.com.

In order to ascertain that such a request has been submitted by you, we ask you to enclose a copy of your ID. When you do this, to protect your privacy, please, black out your passport photograph, MRZ (Machine Readable Zone, ie. the bar with numbers at the lower end of your passport), passport number, and personal identification number on the copy. We will respond to your request as soon as possible and no later than within four weeks.

Cluetail Ltd. also wishes to draw your attention to the possibility of submitting a complaint with the Data Protection Ombudsman (Tietosuojavaltuutettu, at http://www.tietosuoja.fi/en/), the Finnish supervisory authority for data protection.

How we protect personal data

Cluetail Ltd. takes protection of your data seriously and is committed to taking appropriate measures to prevent misuse, loss, unauthorized access, unwanted publication, and unpermitted modification. If you have the impression that your data are not sufficiently protected or that there are indications of misuse, please, contact us via email at info@cluetail.com.

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