Cluetail Ltd. (hereafter ‘Cluetail’), 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 to comply with the General Data Protection Regulation (GDPR) (EU) 2016/679.
Business ID (also VAT number): FI17473488
Cluetail 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;
- Telephone number;
- E-mail address;
- Other personal data which you actively submit, for example, by creating a user profile, in written correspondence, through interactions via social media, or in telephone conversation;
- 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 email@example.com so that we can remove such information.
Purposes of our personal data processing
Cluetail processes your personal data for the following purposes:
- To process your payment;
- To send our newsletter, announcements and other information;
- 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 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 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 processes personal data on the following GDPR-compliant legal grounds:
- 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 does not take decisions which can have (material) 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.
How long we keep personal data
Cluetail keeps your personal data no longer than necessary in order to achieve the goals for which they have been collected.
In case Cluetail has invoiced you, or you have invoiced Cluetail, 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 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. Third parties, including cloud providers of email, storage and marketing automation solutions, may process your data on our behalf. Examples include Google, Dropbox and HubSpot.
Cookies and similar technologies
Cluetail uses functional and analytical cookies, and we may use 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.
Tracking cookies can share the browsing behavior of users between different websites. Cluetail may use tracking cookies for legitimate communications and marketing purposes.
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. 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 a party 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 firstname.lastname@example.org.
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 also wishes to draw your attention to the possibility of submitting a complaint with the Data Protection Ombudsman (Tietosuojavaltuutettu, at https://www.tietosuoja.fi/en/), the Finnish supervisory authority for data protection.
How we protect personal data
Cluetail 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 email@example.com.