1 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2 RELEVANT LEGISLATION
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact us for clarification.
3 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:
3.1 SITE VISITATION TRACKING
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 5 below).
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Cookiebot”. Details on how “Cookiebot” works can be found here.
The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
3.2 CONTACT FORMS AND CLIENT PORTAL
We share customer data with third parties that provide marketing measurement services. This data may include:
- Email address
- Phone number
Situations in which we collect customer data:
- Purchasing a product from the online store
- Subscribing to a newsletter or other marketing communication
- Sending a request for proposal form or other contact form
- Creating a user account
- Other situations in which the above information is collected and separate consent is requested for the use of the information in marketing
By accepting marketing cookies, you agree to the sharing of customer data with third parties for the purpose of marketing measurement.
3.3 EMAIL NEWSLETTER
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to Mailigen who provide us with email marketing services. We consider Mailigen to be a third party data processor (see section 5 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within Mailigen database for as long as we continue to use Mailigen’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the Mailigen database, you will receive periodic (approximately four times a year) newsletter-style emails from us.
4 ABOUT THIS WEBSITE’S SERVER
This website is hosted by Seravo Oy in Finland.
5 OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. All 2 of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
6 DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
7 DATA CONTROLLER
The data controller of this website is: Spoken Oy, a Finnish Private limited company (osakeyhtiö) with company number: FI26286633
Whose registered office is:
Urho Kekkosen katu 4-6 E
00100 Helsinki, Finland
8 RESPONSIBLE FOR DATA PROTECTION
CEO, Spoken Oy
Telephone: +358 50 359 8330
9.1 CHANGE LOG
- Business address updated 14.4.2022
- Server provider and third party data processors updated 19.12.2022
- Remarketing section added 19.12.2022
- Information about Real Cookie Banner added 9.8.2023
- Real Cookie Banner information removed and replaced with Cookiebot information 9.11.2023