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Privacy Policy

1 Controller

Neemo Ltd

Business ID: 2794880-3

Address: Haapaniementie 3, 70100 Kuopio, Finland

2 Contact person

Nanna Hänninen

contact@neemomethod.com

3 Which of your personal data do we process?

We process data related to the following data categories and information pertaining to related changes in the below contexts:

3.1 Data concerning orders and customer profiles

First and last name
Contact information (postal address, e-mail address, telephone number)
The content of your orders, including photographs, order tracking data and information concerning your order history
Complaints, feedback and other contacts, communications and measures related to your customership, including recorded telephone calls and the activities of the data subject related to the controller on social media services
Data concerning the use of Neemo’s other services, such as Neemo’s newsletter subscriptions
Direct marketing permissions and bans
Marketing measures targeted at you and their use, and newsletter tracking data that indicates whether you have opened our newsletter

3.2 Data automatically collected on the use of Neemo’s website

In addition to the personal data described above, we also process your personal data when you visit our website even if you have not registered as our customer or logged onto our service. During your visit to our website (www.neemomethod.com), we process the following data using cookies, Facebook pixels and other similar technology:

Data concerning your main device and online behaviour (e.g. IP address, browser type and browsing history)
The time of browsing and duration of sessions
The links or ads you have clicked on and the ads or other contents you have viewed
Data obtained and profiled using analytics and tracking technology

Your personal data may also be combined with data collected via other services.

4 Do I have to give you my personal data?

We need the personal data we collect from you when you place an order in order to complete your order. In addition, we process certain types of personal data, such as those related to complaints and direct marketing permissions based on our legal obligations.

The failure to provide certain personal data may render us unable to deliver your order and conclude an agreement with you on selling you our products, which means that we will be unable to sell you our products.

5 Where do we collect your personal data?

We particularly collect data from you personally as you provide us with your information when using our services. For instance, you may submit your information to us when placing an order. We also collect personal data in connection with campaigns and serving our customers as well as when you subscribe to our newsletter.

We also collect and update personal data based on the registers of the Population Register Centre, and companies or authorities providing us with addresses, updates and similar services.

We also collect your personal data via your main devices using cookies or other similar technology.

6 For which purposes do we collect and process your personal data?

6.1 Customer management and provision of services

We process your personal data to manage, administer and develop customer relations. We need your personal data to provide you with our services, including shipping your orders.

We also process your data for the purpose of the processing of complaints, errors and other incidents.

6.2 Communications, marketing and profiling targeted at customers

We also process personal data to communicate with our customers both when providing customers with a confirmation of their orders and shipping, and related communications. We also use your personal data for the purpose of Neemo’s direct marketing and other marketing as well as marketing surveys and opinion polls, including electronic direct marketing.

For the purpose of providing our customers with interesting contents, we may analyse and profile the data processed in our register, including information concerning orders and the use of our services, to target our marketing communications. We do not perform automated decision-making based on profiling or other means.

6.3 Developing services

We also process personal data for the purpose of analysing and developing our services and other business activities as well as compiling statistics.

We also process personal data for the purpose of preventing and investigating possible misuse.

7 What is the legal basis for the processing?

7.1 Legitimate interest

Our right of processing your personal data is primarily based on a legitimate interest emerging from the customer relationship. We process your data for purposes such as providing our services, marketing and selling our products to the extent necessary for carrying out these tasks. We also process your personal data to create profiles and send marketing material based on our legitimate interest.

In accordance with the requirements set in data protection legislation and instructions by the authorities, we have assessed that your interest, basic rights or freedoms do not override out legitimate interest in processing your personal data as described in the present data protection policy. You may exercise your rights described in sections 11 and 12 of this policy if you wish to oppose or restrict the processing of personal data that we carry out.

7.2 Agreement

We also process your personal data to implement an agreement concluded between you and our company as well as to carry out measures preceding making the agreement upon your request. An agreement is made between the party you represent and Neemo when you accept our terms of delivery and order our services.

7.3 Consent

We process your personal data based on consent for the part where we request your consent for sending electronic direct marketing to you. We also process other personal data collected with cookies and other tracking technology based on your consent to our cookie policy.

You are entitled to withdraw your consent for the processing of personal data at any given time by contacting the contact person identified in section 2 of this policy or, in case of electronic direct marketing, clicking on a link included in our marketing e-mails.

7.4 Legal obligation

We process your personal data for the purpose of fulfilling our legal obligation when processing your personal data to fulfil our obligations concerning accounting or disclosing data to the authorities.

8 For whom do we transfer or disclose personal data?

We disclose personal data within the limits of valid legislation.

Where necessary, we will also disclose data for parties with a legal right to obtain the data, such as competent authorities.

We transfer data to IT service providers, an accounting firm and other service providers we use in order to store and process the data for the purposes determined by, and on behalf of, Neemo in accordance with our instructions.

9 Transfer of data to third countries

We will not transfer your personal data outside the EU and EEA.

10 How long will we store your data?

We store personal data for as long as necessary for the purposes or the processing of personal data or fulfilling our legal obligations or obligations pertaining to an agreement.

We will store data on orders and information collected in connection with our customer services for ten (10) years since the end of the calendar year when you used our services, placed an order or contacted our customer services.
We will store any personal data necessary for us to fulfil our obligations concerning accounting for ten (10) years since the end of the financial year when the data were collected.
If you have subscribed to our newsletter, we will store your personal data for as long as you stay subscribed to the newsletter. If you unsubscribe to our newsletter or withdraw you consent for electronic direct marketing, we will stop sending you the newsletter without undue delay but will store the information on the marketing ban after you have unsubscribed to the newsletter for as long as we still process your personal data for other purposes.
We will store your personal data collected using cookies and other tracking technology for two (2) years.

11 The rights of the data subject: How can you influence the processing of your personal data?

The data protection legislation guarantees you rights that have been described below. These rights strengthen your right to privacy and provide you with an opportunity for controlling the processing of your personal data.

Without undue delay and within six months since you have contacted us, we will provide you with information about the measures we have taken to ensure your rights are protected as a result of requests related to the implementation of your rights.

If you present a number of requests or if your request is exceptionally complicated, we may postpone the date for providing you with an answer by at most two (2) months. We will separately inform you of such a delay.

You may present a request concerning a right described in section 11 of this policy by mail to the contact person named in section 2. Please note that we may ask you to submit further information if this is necessary for verifying your identity.

11.1 Right to access to data

You have the right to obtain our confirmation on whether we process data concerning you. You also have the right to gain access to the personal data concerning you and the right to obtain information on the processing of personal data in accordance with the General Data Protection Regulation.

When you exercise your right to access the data, we will provide you with a copy of the personal data concerning you that we process. We provide this information in a generally used electronic format unless you explicitly request some other format which we can reasonably produce.

We may charge a reasonable fee based on administrative costs if you request a number of copies or submit recurrent requests.

We cannot provide you with any information that could reveal trade secrets or violate the rights or freedoms of another person. For instance, we will not disclose you the personal data of any other person despite possible requests to do so.

11.2 Right to rectification

You have the right to obtain from us rectification of inaccurate and erroneous data concerning you without undue delay. You also have the right to have incomplete personal data completed by means of providing a supplementary statement.

11.3 Right to erasure

You have the right to obtain from us the erasure of personal data concerning you without undue delay if:

your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (for instance, if your personal data are no longer needed in customer management or similar purposes);
you withdraw your consent for processing your personal data based on grounds relating to your particular situation, and where there is no other legal ground for the processing;
you object to the processing of your personal data for direct marketing purposes;
we have unlawfully processed your personal data; or
your personal data must be erased to ensure compliance with a legal obligation applicable to us.

11.4 Right to restriction of processing

You have the right to obtain from us restriction of processing under which, in addition to storing the data, the personal data may only be processed with your explicit consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person if:

you contest the accuracy of your personal data, in which case the processing will be restricted for a period enabling us to verify the accuracy of the personal data;
the processing is unlawful, but you oppose the erasure of the personal data and request the restriction of their use instead;
we no longer need the personal data for the purposes of the processing described in section 6 of this policy, but you need the data for the establishment, exercise or defence of legal claims; or
you have objected to processing pursuant to grounds relating to your particular situation pending the verification whether our legitimate grounds override those of you as the data subject.

11.5 Right to data portability

As the data subject, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is carried out by automated means and the processing is either based on your consent (e.g. for electronic direct marketing) or the processing of your personal data is necessary for the implementation of an agreement, such as an order you have placed with us.

The exercise of the right to data portability shall not adversely affect the rights and freedoms of others. The right to data portability shall not apply to the processing of personal data based on our legitimate interest.

12 Right to object to the processing

You have the right to object to the processing of your personal data based on grounds relating to your particular situation if there are no compelling grounds for the processing and the processing is based on our legitimate interest.

In addition, you have the right to object at any time to processing of personal data for direct marketing purposes. Where you exercise your right to object to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

13 The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, the Data Protection Ombudsman in Finland, if you consider that the processing of your personal data has violated your rights based on data protection legislation, particularly the General Data Protection Regulation.

14 How will we ensure the security of your personal data?

It is crucial for us to ensure the appropriate protection of your personal data. We collect the data to databases protected by firewalls, passwords and other technical solutions. The databases and their backups are located in a locked and guarded facility and the data may only be accessed by certain designated persons.

We have employed contractual means to ensure that the partner processing personal data on behalf of our company is also committed to the protection of personal data as far as the activities of its employees are concerned.

Data available in a manual format is stored in locked premises used by Neemo.

15 Cookies

In order to provide optimal services to our customers, our website (www.neemomethod.com) uses cookies, Facebook pixels and other similar technology. Cookies are small text files that can be submitted to your main device when you visit our website. We use cookies to enable features on our website, including a logging in and shopping cart feature. Cookies make it easier, better and faster for you to browse our website, and improve user experiences.

We use cookies to collect data on the main devices your use and your behaviour when using our service, including information about the website you visited before our website, which browser you use, and the time you spent and pages you browsed on our website. We use these data for purposes such as developing the user-friendliness of our online service, analysing visitor data, customer surveys, personalising our contents, and targeting our communications and marketing as well as managing our ads. To find out what products may interest you, we may collect data on websites you have accessed or products you have purchased in order to market relevant services to you. We use Facebook pixels to also target relevant marketing to you on Facebook.

At any given time, you may disable cookies completely or partly by changing your browser settings. You may also delete previously stored cookies. However, you should note that disabling cookies may affect accessing some features and services on our website or even completely prevent you from accessing them.

16 Changes to this data protection policy

We may occasionally change our data protection practices, for instance, as a result of changes to our practices or in legislation and related interpretation. We recommend that you regularly familiarise yourself with our data protection policy to ensure that you have sufficient information about any changes that have been made.

We include information of the changes made to our data protection practices on our website.

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