ADDSEARCH PRIVACY POLICY FOR CUSTOMERS AND WEBSITE

GENERAL

This Privacy Policy is applicable to AddSearch Oy’s (“AddSearch” or “we”) database of customers and website visitors as well as AddSearch’s marketing database.

This Privacy Policy describes how we process personal data of our website visitors as well as the representatives of our customers and potential customers (all the aforementioned hereinafter “Customers”).

Some of our services might be subject to a separate privacy policy. If a separate privacy policy applies to a particular service, we will post it in connection with the service in question.

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 on our website We will not make substantial changes to this Privacy Policy or reduce the rights of Customers under this Privacy Policy without providing a notice thereof.

Please note that this Privacy Policy only applies to processing of personal data carried out by AddSearch as a data controller. In regard to the data generated by AddSearch’s customers or users when using the Services while using the AddSearch service in their own business, AddSearch processes this personal data as a data processor. In such case the relevant customer shall be considered to be the data controller.

CONTROLLER’S CONTACT DETAILS

Name: AddSearch Oy
Company ID: 2545782-4
Address: PL 8, 02611 Espoo Finland
Email: info@addsearch.com

PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect two types of information concerning the Customers: (i) Customer Data; and (ii) Analytics Data. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with Customer Data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data.

AddSearch may collect and process the following Customer Data: (i) name and contact details (including user names where applicable); (ii) organisation and title (iii) phone number; (iv) e-mail address; (v) communication history; (vi) invoicing and billing information; (vii) data concerning your orders and use of the Services or your interest in our Services; (iix) marketing opt-outs and opt-ins.

Most of the Customer Data is received directly from Customers in connection with the Customer’s use of the Services. In addition, personal information may be collected and updated from service providers and public registers.

Analytics Data we gather in connection with the use of our Services includes for example the following data: (i) Customer’s IP address; (ii) device and device identification number; (iii) operating system; (iv) time of visit; (v) browser type and version; (vi) language settings. (vii) URL route and search history on the page.

Cookies

We use various technologies to collect and store Analytics Data and other information when Customers visit our Services, including cookies.

Cookies are small text files sent and saved on your device that allows us to identify visitors of our websites and facilitate the use of our Services and to create aggregate information of our visitors. This helps us to improve our Services and better serve our Customers. The cookies will not harm your device or files. We use cookies to tailor our Services and the information we provide in accordance with the individual interests of our Customers.

Customers may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. For example, the following links provide information on how to adjust the cookie settings on some popular browsers:

Safari
Google Chrome
Internet Explorer and Edge
Mozilla Firefox

Please note that some parts of our Services may not function properly if use of cookies is refused.

Web analytics services

Our Services use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Services. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.

PURPOSES AND LEGITIMATE GROUNDS FOR PROCESSING OF PERSONAL DATA

Purposes

Personal data is processed by AddSearch for the following purposes:

To provide our Services and carry out our contractual obligations

We process personal data in the first place to be able to offer the Services to our Customers and to run, maintain and develop our business. Personal data may be processed in order to carry out our contractual obligations towards the Customer. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services. If Customer contacts our customer service, we will use the provided information for answering questions and solving possible issues.

For customer communication and marketing

We may process personal data for the purpose of contacting Customers regarding our Services and to inform Customers of changes in our Services as well as to market our Services.

For quality improvement and trend analysis

We may process information regarding the use of the Services to improve the quality of our Services e.g. by analysing any trends in the use of our Services. When possible, we will do this using only aggregated, non-personally identifiable data.

Legitimate grounds for processing
We process personal data to perform our contractual obligations towards Customers and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain Customer relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy.
In some parts of the Services, Customers may be requested to grant their consent for the processing of personal data. In this event, Customers may withdraw their consent at any time.

TRANSFER TO COUNTRIES OUTSIDE EEA

We store personal data in several geographic locations, including areas outside of the European Economic Area. As such, we or our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or the Customer’s domicile.

We will take steps to ensure that the Customers’ 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 or other similar arrangements.

More information regarding the transfers of personal data may be obtained by contacting us on any of the addresses indicated above.

PERSONAL DATA RECIPIENTS

We do not share personal data with third parties outside of AddSearch’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 perform the Services, AddSearch 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 AddSearch’s 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 AddSearch, our Customers or the public in accordance with the law. When possible, we will inform Customers 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 customer 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. Please bear in mind that if you provide personal data directly to a third party, such as through a link on our website, the processing is typically based on their policies and standards.

For other legitimate reasons

If AddSearch 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 all Customers 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 AddSearch’s organization for other reasons than the ones mentioned before, when we have the Customer’s explicit consent to do so. The Customer has the right to withdraw this consent at all times.

STORAGE PERIOD

AddSearch does not store personal data longer than is legally permitted and necessary for the purposes of providing the Services or the relevant parts thereof. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.

Customer Data relating to your use of the Services are typically deleted within reasonable time after you no longer use the Services. We will store Customer’s personal data for as long as the Customer is a registered user of our Services and, thereafter, for no longer than is required by law or reasonably necessary for our legitimate interests for example for claims handling, internal reporting, marketing and reconciliation purposes.

We will store Analytics Data relating to the Services for maximum of 24 months.

CUSTOMERS’ RIGHTS

Right to access

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

Right to withdraw consent

In case the processing is based on a consent granted by Customer, Customer may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Services. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Right to rectify

Customers have the right to have incorrect or incomplete personal data we have stored about the Customer corrected or completed. You can correct or update some of your personal data through your user account in the Services.

Right to erasure

Customers may also ask us to erase the Customer’s 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

Customers may object to the processing of personal data if such data are processed for other purposes than purposes necessary for the performance of our Services to the Customer or for compliance with a legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.

Right to restriction of processing

Customers 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 Services.

Right to data portability

Customers have the right to receive their 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, including the following information: the full name, company name, address, e-mail address and a phone number. We may request the provision of additional information necessary to confirm the identity of the Customer. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

DIRECT MARKETING

Notwithstanding any consent granted beforehand for the purposes of direct marketing, Customer has the right to prohibit us from using Customer’s 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 functionalities of the Services or the unsubscribe possibility offered in connection with any direct marketing messages.

LODGING A COMPLAINT

In case Customer considers our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

INFORMATION SECURITY

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, encryption, firewalls, secure facilities and access right systems. 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 Services, systems, and other assets for security vulnerabilities.
Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of Customers, we will inform the relevant Customers and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.