Askele Privacy Statement

Askele Oy’s (“Askele”, “we”) Privacy Statement helps you understand what personal data we collect about you, why we collect it and how we process your personal data.

Personal data is information that can be used to identify you as a person. For example a name, e-mail address and telephone number are personal data.

What personal data we process

We process the following types of your personal data:

• Basic personal information, such as name, phone number and email address
• User and network traffic data, such as login ID, username and IP address
• Financial information, such as information related to invoices
• Content you upload or submit, such as photos, comments, articles and videos
• Statistics, which show how users use the services and content we offer
• Information provided through job applications

We do not process your sensitive personal information, such as health information, race or religious belief. You can find more detailed information about the processed personal data in the section Askele as a data controller.

How personal data is collected

We usually collect personal data directly from you or other people related to our customer, but we can also collect data about you from our partner companies of which you are a customer of.

We also use cookies and other tracking technologies when you use Askele websites and interact with us by email to optimize your experience with Askele, our products and our sites. See our cookie policy for more information.

In some cases, we may also collect information about you from other sources. These sources may be third-party data collectors, marketing partners of Askele, public sources or third-party social networks.

Why we process personal data

We process your personal data for various purposes, such as:

Purchases and deliveries

• For managing customer and contractual relationships
• Billing
• To provide and deliver our products and services

Support and service improvement

• To develop and improve the quality, functionality and user experience of our products, services and Askele websites
• For customer support of our products and services
• For the interaction between the customer’s contact persons and Askele

Information security

• To identify, mitigate and prevent security threats and abuses

Marketing

• To manage marketing settings
• For sending newsletters
• For identifying and profiling customers and potential customers to improve communication
• For marketing communications

Recruitment

• For processing job applications

You can find information about how personal data is processed in the Askele Insights service on the service’s own Information security and privacy statement page. In the case of the Askele Insights service, Askele acts as a data processor and processes data on behalf of the customer and in accordance with the instructions.

Legal basis for processing your personal data

We process your data based on several different legal bases:

A contract with you

We process your personal data based on a legally binding contract. This usually happens when you apply for a job at Askele. The processing of your personal data, such as resume, application and references, is necessary so that Askele can process requests from job seekers before concluding a contract.

Your consent

Askele may process your personal data based on consent. You can withdraw your consent at any time.

Legitimate interest

Askele has a legitimate interest when we process your data for information security, support and improvement purposes or when you are a customer contact person for our current and potential customers. Your personal data is processed from a business perspective in a way that does not conflict with your privacy rights.

In addition, we process data based on a legitimate interest if you register for a webinar, download content from our website or use our forums, such as our YouTube or LinkedIn channels. The legitimate interest is to provide you with the right content, hold webinars, market and manage your requests. In the section Marketing and profiling, you can get more information about how we process your data for marketing purposes based on a legitimate interest and about your related rights and liberties.

How your personal information is shared

Askele can share your personal data with external third parties in the following situations:

Our forums

If you write a message, comment or do something similar on Askele’s forums, such as YouTube or LinkedIn, anyone with access to such forums can read and use this information. Askele is not responsible for any information you post on such forums.

Business partners

Askele can share your personal data with its partners if it is legal from a business perspective and in accordance with applicable data protection legislation.

Authorities

The police and other authorities can request access to personal data from Askele. In these cases, Askele only releases the information if there is a court order, etc.

When do we use data processors?

Askele uses data processors in processing personal data. These data processors are typically providers of cloud services or other IT services.

When using data processors, Askele enters into a data processing agreement with the processors to protect privacy. If the data processors are located outside the EU/EEA, Askele will ensure the legal grounds for such international transfers on your behalf by using EU model clauses or a similar, currently legal transfer mechanism.

You can find an up-to-date list of the data processors used in the section Askele as a data controller.

You can always request more detailed information about the data processors used by Askele by contacting us at privacy@askele.fi.

How long your data is kept

We store your personal data only as long as it is necessary to fulfill our contractual obligations. When your personal data is processed on another legal basis, such as in accordance with a legitimate interest, the data is stored as long as it is necessary to achieve the purpose of the processing.

Therefore, different storage policies can be applied to personal data based on the type and purpose of the data. Here are some examples:

• When recruiting, Askele deletes your personal data, such as resume, application and other documents, when the recruitment process has ended, usually no more than 6 months after the deadline for submitting the application, unless otherwise agreed with you.
• Another example is contact information stored for marketing purposes, including leads or potential customers. Such personal data will be deleted no later than 24 months after the last registered activity.

What are your rights

You have the right to request an overview of your personal data that we process and you may have the right to data portability. You also have the right to ask us to correct inaccuracies in your personal data.

In addition, you have the right to request the deletion of personal data and to limit or object to the processing of your personal data in accordance with this privacy statement or other service-specific conditions.

Send your requests by e-mail to privacy@askele.fi. We evaluate the rights of the sender to inspect the requested data.  If the request is justified, Askele handles the collection and delivery of the data to the registered person.

You also have the right to file a complaint with the data protection authorities about the processing of your personal data

Marketing and profiling

Legitimate interest

When you interact with us, for example by visiting Askele’s website, downloading content or participating in webinars, we process your personal data based on a legitimate interest. One of the uses of the legitimate interest is the processing of data for direct marketing purposes.

Askele processes your personal data to provide you with appropriate content through direct marketing on social media platforms, e-mail or websites based on your preferences. The processed personal data is aggregated data about you, such as IP address, interests (clicks, etc.), name and device. This is done using technologies such as cookies and is called profiling. Askele can also combine this information with other information we have based on our customer relationship with your company.

The purpose of profiling is to produce customized marketing, to improve your user experience in our services and on our website, and to offer services that match our customers’ preferences. Askele’s services are mainly used as part of work-related activities, and the use of our services is not intended to reveal anything about your private life. Sensitive personal data is not processed. Your personal data is thus processed from a business perspective in a way that, in our opinion, does not endanger your rights and liberties as a private person.

Askele uses e-mail as a tool for marketing communication based on your consent in those cases where national marketing legislation requires consent to e-mail marketing. If you have given your consent, you always have the option to opt out as described below when you receive an email that contains marketing.

The right to refuse marketing communications

You have the right to refuse to receive marketing communications and targeting profiling, and you can do it in the following ways:

1. by following the opt-out instructions in marketing communications
2. by contacting us by email at privacy@askele.fi

You also always have the option to choose cookies for the website via our cookie banner.

Please note that even if you opt out of receiving marketing communications, you may still receive administrative messages from Askele, such as order confirmations and notifications, which are necessary to manage the services offered to customers.

Askele as a data controller

Askele acts as a data controller for various registers and personal data is processed in several different systems. The data security and data protection level of all systems used by Askele has been ensured and a separate data processing agreement has been concluded with all suppliers in order to protect your privacy and fulfill the commitments given to our customers. Personal data is also processed in systems operating outside the EU/EEA area, but for the suppliers of these systems, we have ensured by the necessary means that the supplier is able to commit to a sufficient level of information security to ensure personal data. For suppliers located in the United States, in addition to the data processing agreement, we use EU standard contractual clauses.

Customer register

Askele processes personal data when offering its services to customers. Personal data is processed, for example, in connection with customer service, invoicing, sales services and providing the services.

Personal data in the customer register

In order to be able to offer our customers the best possible service, we store in our systems the information necessary for managing the customer relationship and providing the service. This information includes:

• Contact information (name, email address, phone number, address)
• The person’s role in the company
• Information related to the collection of customer satisfaction
• Communication history related to our customer service, consulting services, invoicing or sales
• Online training recordings

Askele does not process sensitive personal data in its customer register.

The systems used to process the customer register

We currently use the following systems and service providers to process our customer register:

Marketing register

Askele processes personal data when offering its services to customers and potential customers. We process personal data for the following purposes:

• customer and customer relationship management
• newsletters
• marketing communications and direct marketing
• sales
• feedback, market research or other addressed mailing
• customer segmentation
• targeting sales and marketing measures and customer communication online
• producing personal targeted content online
• statistical purposes

Personal data in the marketing register

Typical personal data to be processed are

• Contact information: name, language, phone number, e-mail, address, company information, position in the company, interest information given by the person
• Consents and prohibitions given by the person: direct marketing permissions and prohibitions and information about subscriptions to newsletters
• Behavioral information: information about the person’s behavior in our online services, information about the implementation and results of targeted measures, other information necessary for contacting or targeting
• Chat conversations: contact information, content, quantity, time and duration. Conversations are saved for service development and statistical purposes
  
• Technical identification data: IP address, browser, operating system, device model, cookies and other identifiers

The systems used to process the marketing register

We currently use the following systems and service providers to process our marketing register:

Changes

We encourage you to review the statement regularly. If we make significant changes to our statement that materially change our privacy practices, we may also notify you in other ways, such as by sending an email or posting a notice on our corporate website and/or social media pages before the changes take effect.

The privacy statement is reviewed annually. Last updated: May 5, 2023.

How to contact us

We value your opinion. If you have comments or questions about our privacy statement, privacy concerns, or a possible violation of privacy, please send them to privacy@askele.fi.

We will treat your request or complaint confidentially. We will contact you to resolve your concerns and map out the options to resolve them. We strive to ensure that complaints are resolved in a timely and appropriate manner.

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