Privacy notice

This privacy notice describes how Puro.earth Oy (”Puro.earth”) processes your personal data. The notice applies when you use our products and services or otherwise interact with us. This notice also applies if you are a business customer.

1. What data does Puro.earth collect and process?

Puro.earth collects and processes various types of personal data, where applicable, such as:

• Personal details: Personal details – including your contact details (such as your name, address, phone number, and email address), demographic data (such as your gender, age, language, nationality, professional details, and additional details such as your interests or a segment group), and your national identity number when required for verifying your identity.
• Agreement & transaction data: Agreement & transaction data – such as information about your agreements, orders, purchases, payment status, and invoices; subscriptions and opt-outs; and your other transactions with us such as service requests and messaging with our customer service.
• Online data & identifiers: Online data & identifiers – data that is collected with cookies or similar technologies about your use of our services, such as your browsing activities and segments, your IP address, cookie ID, mobile device ID, details about browser and device, and location.
• Security data: Security data – data that is used for securing the use of our services and our premises, such as your password and login details, and security logs.

2. How does Puro.earth collect information about you?

The personal data which we process about you comes from different sources:

• You: when you order or use our services, when you fill in a form of interest, participate in a survey or competition, create an account, browse our website, or otherwise interact with us.
• Third parties: Third parties, such as public address registers, credit reference agencies, debt collection agencies, installation partners, marketing partners, electricity and insurance companies, and other data providers.

3. What are the purposes and legal bases for processing personal data?

We will use your personal data for predefined purposes based on contract, consent, legal obligation and legitimate interest. We will use your personal data for the following purposes:

3.1 Service delivery & customer service

We collect and use personal data about you to process orders, deliver products and services, to provide customer service and to manage payments, contracts and transactions.

The data needed for delivering services varies depending on the product or service in question. For example, online services may require the user to authenticate. Our customer service handles your requests and messages to serve you. Customer service may also offer you the optimal contract type that we calculate for you. We may communicate with you in contract related matters via phone, mail, email, SMS, chat, automated calls, and other digital channels including social media.

The basis for processing your data for service delivery and customer service is typically the contract. When required by law, we may ask for your consent to deliver certain services, for example, location based services.

3.2 Sales, marketing and stakeholder communications

We may contact you through marketing even if you are not our customer. We will ask for your consent to contact you when required by law, otherwise our contacting is based on legitimate interest. Without consent, we can send automated electronic marketing messages that relate to your customer or business relationship with us, and use traditional marketing channels (e.g. post, telephone, door-to-door), when allowed by law. We also conduct lotteries and contests.

In addition to our own marketing and sales, we use sales and marketing partners who may contact you about our products and services based on their own customer lists, or sell our products and services at their own premises.

Below you can read more about the different types of marketing.

3.2.1 Customer marketing

Customer marketing is electronic automated marketing that is sent without consent to existing customers and business customers where such practice is allowed.

To our business customers (employees of our current and prospective client companies and business partners, other stakeholders) we send offers and information about products, services, promotional events and services that are relevant for their professional role. We send these communications to the work contact address which we have received from the customer, their company, or a public source.

3.2.2 Consent based marketing

We send you automated electronic marketing and newsletters, if you have agreed to subscribe to them. This marketing can contain information about any Puro.earth products and services or about partner products and services. We may also collect marketing consents on behalf of our partners.

3.2.3 Traditional marketing channels

We may use traditional marketing channels (post, telephone, door-to-door) to contact you about our products or services and our partners’ products or services, unless you have blocked the use of your contact details.

3.2.4 Online advertising

We advertise our products and services online to users who visit our website or our partner’s website, by placing retargeting cookies or pixels on the sites that enable us (or a third party acting on our behalf) to show Puro.earth ad to the same user in another website. In order to target you in social media, we may use your phone number or email address unless you have made a marketing block on them. For targeting in mobile applications, we may use data collected about your use of the application, and your CRM data. We also buy advertising services from external companies that target audiences relevant for Puro.earth, with advertisements of Puro.earth products and services, in which case Puro.earth itself does not process the data. Read more about advertising practices in our cookie policy.

3.2.5 What data is used to optimize sales & marketing (“Profiling”)

For marketing and advertising, we use data that is collected during the customer relationship and from customer surveys; online behavioral data; and derived data that for example predicts the users’ interests. Based on these data, we are able to make marketing more relevant and effective, and send you more personalized offers. You may also receive a targeted offer, for example because you have moved recently.

3.2.6 Stakeholder relations

We manage stakeholder relationships by communicating about relevant topics and promoting events which we arrange. Communications are sent directly by email to the contact addresses received from the stakeholders or their company.

3.3 Product and service development

We process personal data to improve and develop better services for our customers, to support our business decision making, and to consider our customers’ feedback and needs. The basis for processing data for product and service development is legitimate interest. This is done, for example, by collecting feedback directly from users using surveys, test panels, interviews, questionnaires and other forms of market research; by utilizing the data generated from the use of our services in analytics; by using recorded or transcribed phone calls for training and service quality improvement; and by testing system functionality with temporary sample data that is collected during normal service use.

Data processing for our product and service development generally happens with de-identified data to the extent possible. In the case that the customer’s real contact details are collected in connection to the survey, or if we conduct interviews personally with the customer, we may inform you specifically about the use of the contact details in connection to the survey or interview. We may occasionally use samples of real data, for example, to test the functioning of our systems.

In analytics, we do not process identifying data, but we aggregate large volumes of service use data in order to create statistical models, reports, predictions and trend analyses for the support of business decision making; create analyses about service / feature performance; and calculate customer segments that are used to improve our sales and marketing as described in Chapter 3.2.5.

3.4 Legal obligations

We process personal data to comply with our legal requirements, for example, accounting and tax laws, and anti-money laundering laws.

3.5 Defense of legal rights & ensuring security of our services and customers

We use personal data to defend and secure our own rights and our customers’ rights. The basis for processing data for the defense of legal claims, debt collection, credit checking, information security, and prevention of fraud and misconduct is typically legitimate interest. Personal data is used for ensuring the security of our products and services, for example, by keeping access logs and system backups, authenticating users, and preventing attacks.

4. Automated decision-making

If we use automated decision-making with legal or similarly significant effects on you, we will inform you in advance. If such automated decision-making is not authorized by legislation, necessary for the performance of or entering into a contract with us, we will ask for your consent.

You can always express your opinion or contest a decision based solely on automated processing, as well as to request a manual decision making process instead by contacting our customer service.

5. How long does Puro.earth store the personal data?

Puro.earth deletes or anonymizes personal data when there no longer is a need for them. Your personal data and transaction information shall not be stored longer than indicated in the attached table.

6. Who can access your personal data?

• Puro.earth group companies

Our group companies may use your personal data for the purposes defined in this notice, based on legitimate interest to the extent permitted by applicable law, including for marketing their products and services to you.

• Commercial partners

We disclose personal data to our commercial partners based on legitimate interest to the extent permitted by applicable law. Examples of such situations include:
Where you have purchased our products and services from a commercial partner, we often may need to exchange data about you as part of managing that relationship.
Our commercial partners include, for example Puro.earth suppliers and online advertising partners as explained in the cookie policy.

• Consent, contract or request

We may share your personal data if we have your consent to do so. Some of our products and services allow you to share your personal data with others. We may also share your personal data with a third party when this is required to fulfill our obligations under contract with you or to fulfill a request by you.

• Our subcontractors

We use subcontractors to provide services. Such subcontractors may have access to your personal information and are processing it on our behalf but they are not allowed to use the personal data for any other purpose than to provide the service agreed with us. We ensure through appropriate contractual arrangements that the processing of personal data is in accordance with this notice. Typical service providers that process personal data include for example telemarketing and sales partners, payment and invoicing partners, and IT software & service providers.

• Mergers and acquisitions

If we decide to sell, merge or otherwise reorganize our businesses, this may involve us disclosing personal data to prospective or actual purchasers and their advisers.

• Authorities, legal proceedings and law

We will disclose your data to competent authorities, such as the police, to the extent required by law. We may also disclose your personal data in relation to legal proceedings or at the request of an authority on the basis of applicable law, or court order or in connection with a trial or authority process, or as otherwise required or permitted by law.

7. Does Puro.earth transfer personal data to third countries?

Some of our service providers and group companies operate internationally, which means that data is occasionally located outside of the European Economic Area. When personal data is transferred outside the EU or the EEA, Puro.earth uses appropriate safeguards, such as the standard contractual clauses provided by the European Commission. You can obtain more information about the transfers by contacting our customer service.

8. How does Puro.earth protect the personal data?

Puro.earth employs appropriate organizational and technical security measures to protect your data from loss or misuse. Where we contract with third-party suppliers to provide services that may enable them to access your personal data, we require them by contract to have similar security controls in place.

9. Cookies

When you use our services or visit our websites, Puro.earth can collect data about your devices using cookies and other similar technologies. Our website may also include cookies and other similar technologies used by third parties. You can get more information about how to manage cookies and online data use by reading our cookie policy.

10. Your rights and how to exercise them

Below, you can see your rights regarding personal data that Puro.earth processes about you.

If you have any question contact our customer service. You can also order a copy of all the personal data that Puro.earth has about you. You can make the request by sending email to contact@puro.earth.

• Right to access personal data

You have the right to be informed about the processing that we do and to request a copy of your personal data.

• Right to correct personal data

You can ask for the information about you to be corrected, if it is not accurate or if it needs to be updated.

• Right to data portability

You are able to obtain and reuse the personal data you have provided us. We can provide a selected set of the data delivered in a machine readable format, where the basis of processing has been either contract or consent.

• Right to deletion

We will delete the data at your request, if it is no longer legitimately needed.

• Right to withdraw your consent

If you have given a consent for data processing, you are always entitled to withdraw your consent.

• Right to object to the processing

You have the right to object to the processing of your personal data on Puro.earth’s legitimate interests, such as developing our products and services, and other purposes explained above in sections 3 and 6 above. Puro.earth may reject your request if there is a compelling reason for continuing the processing.

• Right to restrict the processing

In certain circumstances you have the right to have the processing restricted.

• To opt out from electronic marketing communications and customer surveys

If you no longer want to receive marketing messages from Puro.earth, you can choose to opt out at any time. The easiest way is to click the link at the end of the marketing message.

• To opt out from telephone and postal marketing

If you no longer want to receive marketing calls or postal marketing from Puro.earth, you can contact our customer service or inform the customer service representatives during the marketing call. In addition you can manage your choices through the National opt out register https://www.asml.fi/kieltopalvelut (in Finnish).

• To manage cookies and to opt out from targeted online advertising

If you want to manage cookies on our websites or to opt-out from targeted online advertising, use the controls set out as described in our cookie policy.

You may still receive marketing messages for a short period after opting out.

Please note that you may still receive marketing messages for a short period after opting out while we update our systems. Also, we sometimes use marketing partners, who may display our products and services to you, but who have not received any personal data about you from us. To opt out from such marketing or to exercise your other rights, you will need to contact the specific marketing partner directly.

How to lodge a complaint

If we do not take action in accordance with your requests, we will inform you of the reasons. If you are not satisfied with our response, or with the way we handle personal data, please contact us. If you are still not pleased with the handling, you can contact the national data protection authority.

11. Changes to this privacy notice

Puro.earth reserves the right to amend this Privacy Notice. Possible amendments to the Privacy Notice will be notified about on our website, or by communicating directly to you.

12. Controller of your personal data

The data controller is Puro.earth.

Puro.earth Customer Service

If you have any questions or want to exercise any of your rights, please contact us at contact@puro.earth.

Ordering one’s own personal data

If you want to order a copy of all the personal data that Puro.earth has about you, you can make the request by sending email to contact@puro.earth.

Further questions and comments

Further questions and comments regarding your privacy can be addressed to our dedicated privacy team by sending email to contact@puro.earth.

Puro.earth Oy
Tammasaarenkatu 1
00180 Helsinki
Finland