Tietosuojaseloste

Privacy Policy

This privacy policy, compliant with the EU General Data Protection Regulation (2016/679), describes how Etufillari collects, uses, stores, and protects the personal data of Customers, Users, or customer prospects when visiting Etufillari's website. This privacy policy applies only to the processing of personal data where Etufillari acts as the data controller. Etufillari may update this privacy policy if necessary due to changes in data processing or other reasons. This policy was created on 27.3.2021. The most recent change was made on 18.6.2024. The current version of the privacy policy can be found on Etufillari's website at:www.etufillari.com/tietosuojaseloste.

Contact Details

Official Company Name: Etufillari OyPostal Address: Läkkisepänkuja 2, 02650 EspooBusiness ID: 2093389-5Email Address: info@etufillari.comPhone Number: 09 747 90796

Inquiries Regarding Data Protection

Email Address for Data Protection Inquiries:dataprotection@etufillari.comData Protection Officer:Matias Järvinen, matias@etufillari.com

Processed Personal Data and Sources

Etufillari collects and processes data related to the User, Customer, their contacts, and customer prospects for the marketing and implementation of the Service, such as

name
phone number
email address
customer feedback and satisfaction data

Etufillari collects and processes data of Users approved by the Customer for booking bikes through the Service, such as

name
phone number
email address
language preference
address
content generated by the User in the Service (such as feedback or additional information provided by the User about themselves)

Etufillari primarily collects Customer data directly from Customers and/or customer prospects. User data is primarily collected directly from the User either provided by the User themselves, generated by the Service, based on the use of the Service, and/or from Customers.Etufillari does not process data belonging to special categories of personal data as defined in Article 9 of the EU General Data Protection Regulation.

Purpose and Legal Basis of Processing Personal Data

Etufillari processes the personal data of Customers and Users for the following purposes and legal bases:

To provide the Service and fulfill contractual obligations. Personal data is used to identify the Customer or customer prospect and to deliver orders of Users registered with the Service, maintain and develop the customer relationship. When the Customer or User contacts Etufillari's customer service, Etufillari uses the provided data to respond to the Customer's or User's questions and resolve their issues.
Legal basis: performance of a contract. GDPR Article 6.1.(b)
To comply with legal obligations. Personal data is processed to fulfill Etufillari's legal obligations. This includes processing personal data for accounting obligations and providing data to appropriate authorities as required.
Legal basis: legal obligation. GDPR Article 6.1.(c)
To handle and defend legal claims. Personal data may be processed in connection with legal claims, debt collection, and legal proceedings. Data may also be processed to prevent fraud or misuse of Etufillari's services and to maintain information, system, and network security.
Legal basis: legitimate interest of the data controller. GDPR Article 6.1.(f)
To conduct marketing and communication. Etufillari may process the personal data of Customers or Users to contact them regarding the Service and to inform them of changes to the Service. Personal data may also be used in the marketing of the Service and other relevant services and products.
Legal basis: legitimate interest of the data controller. GDPR Article 6.1.(f)
To improve the operation of the website and the Service. Data on the use of the Service may be used to improve the quality of the Service by analyzing usage trends. Personal data of Customers or Users may also be used for conducting customer satisfaction surveys.
Legal basis: legitimate interest of the data controller. GDPR Article 6.1.(f)

Disclosure and Transfer of Personal Data Outside the EU or European Economic Area

Collected personal data may be shared with third parties, such as Etufillari's partners and service providers, only to the extent necessary for the purposes described in the Privacy Policy or for preparing, presenting, or defending a legal claim related to the Service.Personal data is primarily processed within the EU area, but some of the external service or software providers used by Etufillari may store data outside the EU or European Economic Area. For example, some of the servers used by Etufillari's website hosting provider are located in countries outside the European Economic Area (Israel, Japan, and the United States). Both of these countries have anequivalence decision from the EU Commission.

Retention Period of Personal Data

Collected personal data is retained as long as necessary to fulfill the contract with the Customer or to develop customer service.

Rights of the Data Subject

Right to access data. The data subject has the right to review their data stored in the register.
GDPR Article 15
Right to rectify data. The data subject has the right to request correction of any incorrect data or completion of incomplete data in the register.
GDPR Article 16
Right to erasure. The data subject has the right to request the deletion of incorrect or inaccurate data.
GDPR Article 17
Right to restrict processing. The data subject has the right to restrict the processing of personal data, for example, when their request for erasure, rectification, or objection is being processed.
GDPR Article 18
Right to data portability. The data subject has the right to receive their data in a structured, machine-readable format and to transfer this data to another data controller or processor.
GDPR Article 20
Right to object to processing. The data subject has the right to object to the processing of their personal data based on their specific personal situation, to the extent that this processing is based on GDPR Article 6.1(f).
GDPR Article 21

The aforementioned rights of the data subject can be exercised by sending a letter or email to the postal or email address mentioned in the Privacy Policy, including the following necessary information: name, address, email address, phone number. Etufillari may request additional information necessary to verify the identity of the Customer or User. Etufillari may reject requests that are unreasonably repetitive, excessive in nature, or clearly unfounded.

Automated Decision Making

Customers or Users are not subject to automated decision-making or profiling as defined in Article 22 of the EU General Data Protection Regulation.

Use of Cookies

cookiesUsage.description1Cookies used by Etufillari can be divided into persistent and session cookies. Session cookies are automatically destroyed when the browser is closed. Persistent cookies are automatically removed from the device after a specified retention period (unless the Visitor disables the cookie before this time).Cookies used on Etufillari's website can be divided into Essential and Functional. Essential cookies are necessary for the operation of the site and enable functions such as chat messages on the site. Functional cookies are not necessary for the operation of the site but help the site remember the visitor's language preference.If the Visitor wishes, they can disable the cookie function in most browsers by selecting it in the browser settings.However, cookies may be necessary to ensure the proper functioning of some of the pages and services maintained by Etufillari.Below are described the cookies used by the site.

Cookies Used by the Site

Cookie Name	Purpose of Use	Storage Duration	Cookie Type
accessToken	Used for user authorization in subsequent requests.	24 Hours	Necessary
refreshToken	Used to obtain a new access token without re-authenticating the user.	14 Days	Necessary

For more general information about cookies, including managing and deleting them, you can visithttps://www.aboutcookies.org/orhttps://allaboutcookies.org/.Some of the third-party cookies used by Etufillari are web analytics services and other web analytics tools used by the Service to compile analytics data and reports on the use of the website (Google Analytics, Hubspot). More information about Google Analytics can be found on the Google Analytics website. You can opt-out of data collection by Google Analytics by downloading the following browser add-on:Google Analytics opt-out add-on.

Filing a Complaint

If the Customer or User believes that the processing of personal data related to the Service is in violation of applicable data protection legislation, they can file a complaint with the local supervisory authority, which in Finland is the Data Protection Ombudsman. (www.tietosuoja.fi).