Theymes Privacy Policy

This Privacy Policy applies to the personal data processed by Theymes (“Theymes” or “we”) relating to the users of the website, products, and services provided by Theymes (hereinafter jointly refered to as the “Services”). This Privacy Policy also applies to personal data processed by Theymes in regard to the representatives of our vendors, business partners, or customer organizations, including personal data processed within our CRM databases or in connection to our marketing activities. All of the aforementioned data subjects are hereinafter collectively referred to as “Users” or “you”.

The purpose of this Privacy Policy is to provide you with information about the processing of your personal data in accordance with the information obligations set in Articles 13 and 14 of the General Data Protection Regulation 2016/679 (“GDPR”).

Please note that this Privacy Policy only applies to processing carried out by Theymes as a data controller.

This Privacy Policy does not address, and we are not responsible for, the privacy and data processing practices of any third parties.

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website www.theymes.com. We will not make substantial changes to this Privacy Policy or reduce your rights under this Privacy Policy without providing a notice thereof.

Contact Details

Company Theymes Oy Business ID: 3369440-8

Correspondence address c/o Theymes Oy Sibeliuksenkatu 10 C 4 04400 JÄRVENPÄÄ Website: www.theymes.com

Contact: contact@theymes.com

PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect two types of information concerning our Users: (i) User Data; and (ii) Analytics Data.

User Data is primarily received directly from you either in connection with your use of the Services or in connection with your other business interactions with us. In certain cases, User Data may also be provided to us by the company or organization you are representing.

Analytics Data is collected automatically as you use the Services. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from the data, either alone or when combined or linked with other data. In such situations, Analytics Data shall also be considered personal data under applicable laws, and we will treat the combined data as personal data.

User Data and Analytics Data typically consist of the following categories of data: User Data

• Contact details, such as name, email address and phone number.
• Employment information, such as organization and title.
• User credentials, such as username and password.
• Technical details and details relating to your use of the Services, such as service settings and metadata.
• Other information you choose to provide in any direct correspondence with us.

Analytics Data

• Unique identifiers, such as IP address and cookie IDs.
• Device information, such as device type and model, browser type and version, and operating system.
• Information about user activity and service performance, such as platform visits and time and duration of visits.

COOKIES AND ANALYTICS TOOLS

We use certain technologies to collect and store Analytics Data when you use our SaaS platform, including cookies. Cookies are small text files sent and saved on your device that allows us to identify you when you use our platform and facilitate and create aggregate information of the use of our platform. This helps us to improve our platform and better serve our Users. The use of any cookies other than technically necessary cookies is based on the consent of the User, which the User may revisit and withdraw at any time. Please note that some parts of our platform may not function properly if use of cookies is refused.

PURPOSES AND LEGITIMATE GROUNDS OF PROCESSING

Personal data is processed by Theymes for the following purposes.

Provision of the Services and carrying out contractual obligations Legal ground: Performance of a contract and legitimate interests

We process personal data to be able to offer the Services to our Users and to run and maintain our business. Personal data may be processed to carry out our contractual obligations towards the Users and the organizations represented by the Users. We may use the data for example to administer the accounts, orders, and payments of the Users’ organizations, and to provide access to and offer essential functionalities of the Services.

Legal obligations

Legal ground: Compliance with a legal obligation

We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities.

Communication and marketing

Legal ground: Legitimate interest

We may process personal data for the purpose of contacting you regarding the Services Theymes provides to you, or the services your organization provides to us.

We may also process personal data to advertise and market our Services to you and your organization as our current or prospective customer.

For quality improvement and trend analysis

Legal ground: Legitimate interest

We may process information regarding your use of the Services to improve the quality of our products and services, for example by analyzing any trends in the use of our Services. Where possible, we will do this using only aggregated, non-personally identifiable data.

Claims handling and legal processes

Legal ground: Legitimate interest

We may process personal data in relation to claims handling, debt collection, and legal processes. We may also process data for the prevention of fraud, misuse of our Services, and for data, system, and network security. Mergers, acquisitions, asset sales, and other reorganizations of our business may also involve the processing of your data for the purposes of the reorganization.

LEGAL GROUNDS FOR PROCESSING

We primarily process personal data on a contractual basis. For individuals acting as representatives of our customer or partner organizations, personal data is primarily processed based on our legitimate interest whilst fulfilling our contractual obligations towards the organizations they represent.

We may also process personal data based on our legitimate interests when maintaining our business, for example in connection with analytics and marketing. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.

In certain cases, you may be requested to grant your consent for the processing of your personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.

INTERNATIONAL TRANSFERS

Theymes stores personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area or outside of your domicile.

We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through agreements with our service providers based on the European Commission’s Standard Contractual Clauses or another appropriate transfer mechanism.

PERSONAL DATA RECIPIENTS

Personal data may be shared to the following third parties outside of Theymes’ organization in the circumstances explained below.

Authorized service providers

We may share personal data to authorized service providers who perform services for us (including IT services, data storage, sales, marketing, and support services). Our agreements with our service providers include commitments where the service providers agree to limit their use of personal data and to comply with appropriate privacy and security standards.

Authorities and government agencies

We may share personal data with authorities, government agencies, and advisors outside of our 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 Theymes, our Users, or the public in accordance with the law. When possible, we will inform you about such transfer and processing.

Reorganizations

If Theymes is involved in a merger, acquisition, asset sale or other reorganization, we may transfer personal data to the third parties involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to those concerned when the personal data are 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 of our organization for other reasons than the ones mentioned before, when we have your explicit consent to do so. You have the right to withdraw this consent at all times.

STORAGE PERIOD

Theymes does not store personal data longer than is legally permitted and necessary for purposes of providing the Services or maintaining another business relationship with you, or for another individual purpose for which your personal data is being processed. The storage period depends on the nature of the information and the purposes of processing. The maximum periods therefore vary per use but include the following. User Data

User Data will be retained for as long as you are using the Services or acting as a representative of an organization using or contemplating the use of the Services, and for a maximum period of two years after that. In case you are acting as a representative of our vendor or business partner, your data will be retained for as long as you are representing such organization in the business relationship, and for a maximum period of two years after that.

User Data will, however, be deleted already earlier, if they are no longer needed for the purposes of processing specified in this Privacy Policy, or if you request the deletion of your personal data, unless we have a legal ground to retain such data.

Statutory retention period may also apply to certain User Data. For example, User Data that is included in accounting materials are retained for six years, in accordance with accounting law.

Analytics Data will be retained for a maximum period of two years.

Analytics Data will, however, be deleted already earlier, if they are no longer needed for the purposes of processing specified in this Privacy Policy, or if you request the deletion of your personal data, unless we have a legal ground to retain such data.

INFORMATION SECURITY

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, availability, resilience, and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects on 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 possible.

YOUR RIGHTS

Right to access

You have the right to access your personal data processed by us. You may contact us, and we will inform what personal data we have collected and processed regarding you.

Right to withdraw consent

In case the processing is based on a consent you have granted to us, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Please note, that withdrawing your consent may lead to fewer possibilities to use our Services.

Right to rectification and erasure

You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us. You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.

Right to object

You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Service or for compliance with a legal obligation. Please note, that objecting to the further processing of your personal data may lead to fewer possibilities to use our Services.

Right to restriction of processing

You may request us to restrict the processing of your personal data for example when your data erasure, rectification, or objection requests are pending and/or when we do not have legitimate grounds to process your data. Please note, that this may however lead to fewer possibilities to use our Services.

Right to data portability

You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those 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 above. We may request the provision of information necessary to confirm your identity.

LODGING 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.

In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).