Diktamen Oy (“Diktamen” or “we”) collects and processes personal data of users of our online services and website. This Privacy Policy applies to personal data we obtain from individuals (“Users” or “you”) through our websites, online services, and web-based applications (collectively, the “Services”). In regard to this data, we shall be acting as a data controller in the meaning of the EU’s general data protection legislation (GDPR).

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 on the relevant website or otherwise make it available in connection with the service in question.

This Privacy Policy explains what data we process, how we do that and how the data subjects, i.e. you, may use your rights (e.g. right to object, right of access). Privacy, security, and online safety are important for us, and we process all personal data with due care and in accordance with applicable laws and regulations.

1. WHAT INFORMATION WE WILL COLLECT ABOUT YOU?

We collect the following information types from you:

(i) User Data;

During your use of the Services, we may collect and process for example the following User Data from you:
– first and last name;
– e-mail address;
– phone number;
– Name and information regarding the organization you represent;
– information that you provide when rating our Services or giving feedback on our Services;
– and any other personal data you may provide yourself.

The specific kind of User Data collected will depend on the Services used. User Data is received directly from you.

(ii) Technical Data;

Technical Data may include for example the following data;
– Your IP address;
– browser type and version;
– preferred language;
– geographical location using IP address or the GPS, wireless, or Bluetooth technology on your device;
– operating system and computer platform;
– the full Uniform Resource Locator (URL) clickstream to, through and from our Services, including date and time;
– and areas of our Services you have visited.

Although we do not normally use Technical Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with User Data. In such situations, Technical Data can also be considered to be personal data under applicable laws, and we will treat the combined data as personal data.

2. WHEN CAN WE PROCESS YOUR PERSONAL DATA?

There are several purposes for the processing of personal data by Diktamen:

– 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 you and to run, maintain and develop our business. We process and use personal data for example to provide essential functionalities for customers and Users, i.e. in order to match customers with Users and vice versa. In some cases, personal data may be processed in order to carry out our contractual obligations towards you. We may use the data for example to offer essential functionalities of the Services and to provide access to the Services. If you contact our customer service, we will use the provided information for answering questions and solving possible issues.

– For customer communication

We may process personal data for the purpose of contacting you regarding our Services and to inform you of changes in our Services. Data may also be used for research and analysis purposes in order to improve 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.

– For statistical and analytical purposes

Diktamen may gather Technical Data and other anonymous and aggregate data in order to generate reports and statistics. We may use statistics and reports for sales and marketing purposes. In addition, we may provide customers and you with the aforementioned statistics and reports. For clarity, such statistics and reports do not include any personal data.

– For other legitimate purposes

We process personal data for the purposes of direct marketing, such as the sending of newsletters or similar marketing material. You can unsubscribe from receiving such material at any time.

In some parts of the Services, you may be requested to grant their consent for the processing of personal data. In this event, you may withdraw their consent at any time.

3. WILL MY PERSONAL DATA BE TRANSFERRED OUTSIDE THE EU?

The data handled within our service platform for investors and founders are stored within the EU/EEA.
For our website functions, we use service providers in several geographical locations, such as Google Analytics. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or your domicile. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. We provide adequate protection for the transfer of personal data to countries outside of the European Economic Area through a series of intercompany agreements and 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 addresses mentioned in this Privacy Policy.

4. WILL DIKTAMEN SHARE MY PERSONAL DATA WITH ANYONE ELSE?

We only share personal data within the organisation of Diktamen if and as far as reasonably necessary to perform and develop our Services.

We do not share personal data with third parties outside of Diktamen’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, Diktamen 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 Diktamen’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 Diktamen, you or the public in accordance with the law. When possible, we will inform you 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, payment service, marketing and customer support service providers). 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 Diktamen 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 you when your personal data is 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 Diktamen’s organization for other reasons than the ones mentioned before when we have your explicit consent to do so.

Due to the functionalities of our Services, your personal data might be transferred to Diktamen’s customers. When a customer searches for suitable employees, only the current title, domicile and competences of the relevant User are visible to the customer. In order to apply for a certain position or to submit an application to certain customer, you will be required to give consent for the transfer of your personal data to said customer. You will remain anonymous until you have separately consented to the transfer of your identification and personal data to a certain customer. By giving the consents and permissions, you warrant and represent that you are allowed and permitted to give such consents and permissions.

5. HOW LONG DO WE STORAGE YOUR PERSONAL DATA?

Diktamen 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.

Typically, we will store your personal data for as long as you are a registered subscriber or a registered user of our Services or for as long as we have another purpose to do so and, thereafter, for no longer than is required or permitted by law or reasonably necessary for internal reporting and reconciliation purposes.
In general, your personal data is deleted within a reasonable time after you no longer use any part of the Services or when you make a request regarding deletion of your personal data.

6. WHICH ARE MY RIGHTS?

Right to access
Diktamen offers access for you to the personal data processed by Diktamen. This means that you may contact us and we will inform what personal data we have collected and processed regarding you and the purposes such data are used for.

Right to withdraw consent
In case the processing is based on a consent granted by you, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Services.

Right to correct
You have the right to have incorrect, imprecise, incomplete, outdated, or unnecessary personal data we have stored about you corrected or completed.

Right to deletion
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. We may not immediately be able to delete all residual copies from our servers and backup systems after the active data have been deleted. Such copies shall be deleted as soon as reasonably possible.

Right to object
You may object to certain use of personal data if such data are processed for other purposes than purposes necessary for the performance of our Services to you or for compliance with a legal obligation.
You may also object any further processing of personal data after prior given consent. If you object the further processing of personal data, this may lead to fewer possibilities to use our Services.

Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling 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.

Right to restriction of processing
You may request us to restrict certain processing of personal data, this may, however, lead to fewer possibilities to use our Services.

Right to data portability
You have the right to receive their personal data from us in a structured and commonly used format and to independently transmit that 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 below, including the following information: name, address, phone number and a copy of a valid ID. We may request the provision of additional information necessary to confirm your identity.
We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

7. WHAT IF I WANT TO MAKE A COMPLAINT?

In case you consider 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

8. USE OF THIRD PARTY SERVICES

This Privacy Policy only covers data processing carried out by us. The Privacy Policy does not address, and we are not responsible for, the privacy practices of any third parties. We disclaim all responsibility for the processing carried out by third parties, also in cases where Services include hyperlinks or other links to third parties’ websites or services. If you leave our website to visit third parties’ websites, we highly encourage you to read their privacy notices on their websites.

9. MARKETING

We would like to send you information about our Services. If you have given your consent to receive marketing, you may opt out at a later date. You always have a right to stop us from contacting you for marketing purposes.

10. INFORMATION SECURITY

It is our responsibility to protect our platform and data with best possible solutions.

We take all reasonable and appropriate security measures to protect the personal data we store and process from unauthorised access or unauthorised alteration, disclosure or destruction. Measures include for example, end-to-end TLS communication encryption and encryption of sensitive user information. We monitor data security threats and solutions and take them into account in our platform solutions and architecture.

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, and availability. We regularly test our websites, data centers, systems, and other assets for security vulnerabilities.

Should despite the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as reasonably possible.

For more information, contact our technical staff with email at techsupport@diktamen.com

11. UPDATING OUR PRIVACY POLICY

We may update this Privacy Policy 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 your rights under this Privacy Policy without providing a notice thereof.

12. HOW TO CONTACT US

Please contact us, if you have any questions about our Privacy Policy or information we hold about you.

By email: info@diktamen.com
Or visit our website: https://www.diktamen.com

13. KEY LEGAL INFO

Main office: Itämerenkatu 1, 00180 Helsinki, Finland
Manchester Office (Sales, UK & International): MedTech Centre, Greenheys Building, Pencroft Way, Manchester Science Park, M15 6JJ

Name: Diktamen Oy.
Registered in Finland with company identification number 2106590-3.