1. CONTROLLER

Nosto solutions Oy

Bulevardi 21, 00180 Helsinki

+358 20 735 4880

legal@nosto.com

(hereafter ”we” or ”Nosto”)

2. CONTACT PERSON FOR REGISTER MATTERS

Legal Department

Bulevardi 21, 00180 Helsinki

legal@nosto.com

3. NAME OF REGISTER

Customer and marketing register

4. What is the legal basis for and purpose of the processing of personal data?

The basis for processing personal data is the legitimate interest of the company based on customer relationship or other appropriate connection.

The purpose of the processing of personal data is:

We use profiling to identify the data subjects’ personal profiles, online behaviour, age, consumer habits. We use this information to target marketing and to develop services. For more information please see our separate Cookie Notice.

5. What data do we process?

We process the following personal data of the customer or other data subject in connection with the customer register:

6. From where do we receive information?

We receive data primarily from the following sources from the data subject himself (from events), from the population register, from our partners, from the authorities, from credit information agencies, from contact information serviceproviders and from other similar reliable sources.

For the purposes described in this Privacy Notice, personal data may also be collected and updated from publicly available sources and based on information received from authorities or other third parties within the limits of the applicable laws and regulations. Data updating of this kind is performed manually or by automated means.

Nosto provides certain services that enable connections with and data ingestion from Social Networks.

7. To whom do we disclose data and do we transfer data outside of EU or EEA?

We do not disclose data from the register to external parties.

We use subcontractors that process personal data on behalf of and for us. We have outsourced the IT- and marketing management to an external service provider, to whose server the data is stored. The server is protected and managed by the external service provider

We transfer personal data outside of EU/EEA (the United States of America, Australia, Germany, Ireland, Israel, Japan, and the UK). We have taken care of suitable safeguards for the transfer. We use standard contractual clauses accepted by EU or  Privacy Shield -framework where applicable.

8. How do we protect the data and how long do we store them?

Only those of our employees, who on behalf of their work are entitled to process customer data, are entitled to use a system containing personal data. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies of them are in locked premises and can be accessed only by certain pre-designated persons.

We store the personal data for as long as is necessary considering the purpose of the processing. Max. 2 years from the date when data subject has last time showed activity.

We regularly assess the need for data retention in light of the applicable legislation. In addition, we take reasonable measures to ensure that the personal data in the register is not incompatible, obsolete or inaccurate considering the purpose of the processing. We rectify or delete such information without delay.

9. What are your rights as a data subject?

As a data subject you have a right to inspect the personal data concerning yourself, which is stored in the register, and a right to require rectification or erasure of the data, provided that the request has a legal basis. You also have a right to withdraw or change your consent.

As a data subject, you have a right, according to EU’s General Data Protection Regulation (applied from 25.5.2018) to object processing or request restricting the processing and lodge a complaint with a supervisory authority responsible for processing personal data.

For specific personal reasons, you also have the right to object to profiling and other processing operations, when the processing of your data is based on our customer relationship with you. In connection with your request, you will need to identify the specific situation, based on which you object to the processing. We can refuse the request of objection only on legal grounds.

As a data subject you have the right to object to processing at any time free of charge, including profiling in so far as it relates to direct marketing.

10. Who can you be in contact with?

All contacts and requests concerning this Privacy Notice must be submitted in writing or in person to the person mentioned in section two (2).

11. Changes in processing

Should we make amendments to this Privacy Notice we will place the amended statement on our website, with an indication of the amendment date. If the amendments are significant, we may also inform you about this by other means, for example by sending an email or placing a bulletin on our homepage. We recommend that you regularly visit out webpage and notice possible amendments to this Privacy Notice. review these privacy protection principles from time to time to ensure you are aware of any amendments made.