Adalyon privacy policy

This Privacy Policy is applicable to the personal data processed by Adalyon Oy (“Adalyon” or “we”) relating to the visitors of the Adalyon website and users of the Adalyon online service (Adalyon website and online service hereinafter jointly refered to as “Service”).
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This Privacy Policy is also applicable to personal data processed by Adalyon in regard to the representatives of our customer organizations, vendors and business partners, including personal data processed within our CRM databases or in connection to our marketing activities. All of the aforementioned data subjects are hereinafter collectively referred to as “Users” or “you.”

Please note that this Privacy Policy only applies to processing carried out by Adalyon as a data controller.

This Privacy Policy does not address, and we are not responsible for, the privacy and data processing practices of any third parties.

Please note that in certain cases we may also process your personal data as a data processor on behalf of the organization you represent. Such processing will be carried out strictly as instructed by the data controller and is not covered by this Privacy Policy.

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found here on our website. We will not make substantial changes to this Privacy Policy or reduce your rights without providing a notice thereof.

Adalyon Oy
Business ID: 3243258-8
Keilaniementie 1, 02150 Espoo Finland
Adalyon.com
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Contact person for data protection related matters:
Darja Husu, darja.husu@adalyon.com

• IP address;
• Device type and model (computer, phone or tablet);
• Operating system;
• Time of visit;
• Browser type and version;
• Service settings and preferences

To provide our Service (legal ground: legitimate interest)

We process personal data to be able to offer the Service to Users and to run and maintain our business. Personal data may be processed in order to carry out our contractual obligations towards the organization the User represents. We may use the data for example to offer essential functionalities of the Service, to provide technical support to customers and to provide access to the Service.

For our legal obligations (legal ground: compliance with a legal obligation)

We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our accounting obligations and providing information to relevant authorities.

For claims handling and legal processes (legal ground: legitimate interest)

We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our Services and for data, system and network security.

For communication and marketing (legal ground: legitimate interest or consent)

We may process personal data for the purpose of contacting our Users regarding our Service and for informing Users of changes in our Service. We may also process personal data to market our Service, for example in the form of sending newsletters.

For quality improvement and trend analysis (legal ground: legitimate interest or consent)

We may process information regarding your use of the Service to improve the quality of our service, for example by analysing any trends in the use of our Service. Where possible, we will do this using only aggregated, non-personally identifiable data. Where personally identifiable data is used, we generally ask for your consent prior to performing any tracking.

International transfers

Adalyon stores personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we, our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of your domicile.

We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses and through other appropriate safeguards, including case-by-case transfer risk assessments and the use technical safeguards such as encryption and pseudonymization.

Personal data recipients

We do not share personal data with third parties outside of Adalyon’s organization unless one of the following circumstances applies:

It is necessary for the purposes set out in this Privacy Policy

To the extent that third parties need access to personal data to ensure the performance fo the Service, Adalyon has taken appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.

For legal reasons

We may share personal data with third parties outside of our organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Adalyon, our Users or the public in accordance with the law. When possible, we will inform you about such transfer and processing.

To authorized service providers

We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.

For other legitimate reasons

If Adalyon is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to those concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.

With explicit consent

We may share personal data with third parties outside of our organization for other reasons than the ones mentioned before, when we have your explicit consent to do so. You have the right to withdraw this consent at all times.

Storage period

Adalyon does not store personal data longer than is legally permitted and necessary for purposes of providing the Service or the relevant parts thereof, or for another individual purpose for which your personal data is being processed. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.

Your rights

Right to access

You have the right to access your personal data processed by us. You may contact us and we will inform what personal data we have collected and processed regarding you.

Right to withdraw

consentIn case the processing is based on a consent you have granted to us, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.

Right to erasure

You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.

Right to object

You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Service or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the our Service.

Right to restriction of processing

You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Service.

Right to data portability

You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those data to a third party.

How to use the rights

The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity.

We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

Direct marketing

Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.

Information security

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. The data that we process is encrypted in rest and transit. We also use SSO. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.
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