LeadSpark Oy respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when: (i) you visit our website (regardless of where you visit it from); and (ii) when we collect personal data from you. It will also tell you about your privacy rights and how the law protects you.Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how LeadSpark Oy collects and processes your personal data, including any data you may provide through this website or when you enter into a contract with, or request services from, us.
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: LeadSpark Oy (Company ID: 2775435-5)
Name or title of data privacy manager: Sami Lahtinen
Email address: email@example.com
Postal address: LeadSpark Oy, Ruoholahdenkatu 14, 00180 Helsinki
Telephone number: +358 40825 3080
You have the right to make a complaint at any time to Finnish Data Protection Authority, the Finnish supervisory authority for data protection issues (https://tietosuoja.fi/en/contact-information).We would, however, appreciate the chance to deal with your concerns before you approach the Finnish Data Protection Authority, so please contact us in the first instance.
This version was last updated on 27 September 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed(anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data including first name and surname and company details (if applicable).
- Contact Data including address,telephone number, mobile number, Skype contact details, and email address.
- Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Usage Data including information about how you use our website and services.
- Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with LeadSpark Oy’s services). In this case, we may have to cancel a service or terminate a contract you have with us.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity and Contact Data by filling in an order form or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Request our services via an order form;
- Request a demo on our website; or
- Request marketing information to be sent to you, or agree that we can send marketing information to you.
Third parties or publicly available sources.We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
(a) analytics providers such as Google;
(b) advertising networks; and
(c) search information providers.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will process your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or haveentered into with you.
- Where it is necessary for our legitimate interests (or those of a thirdparty) and your interests and fundamental rights do not override thoseinterests. This may include marketing our services to you.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you marketing information (if we require consent to do so).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data,and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
With your consent and/or where permitted by law, we may use your data for marketing purposes. This may include contacting you with information, news and offers on our services. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under relevant data protection legislation, including the Privacy and Electronic Communications (EC Directive) Regulations 2003.
You may also receive marketing communications in relation to products and/or services similar to those which you have previously requested from us and you have not opted out of receiving such marketing.
We do not share your personal data with any third party company or entity for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting our data processing manager or the relevant third party. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in connection with the provision of our services to you and any other lawful reason why we may process your personal data.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like further details as to how the processing for the new purpose is compatible with the original purpose,please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may transfer your personal data outside the European Economic Area (EEA) for the purpose of delivering LeadSpark’s services, such as gethaavi.com to you.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By the Finnish law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for up to five years after they cease being customers for legal and tax purposes.
In some circumstances you can ask us to delete your data:see the section entitled Request Erasure below for further information.
In some circumstances we may anonymise your personal data(so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.If you wish to exercise any of the rights set out above, please contact our data protection manager.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you(both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting our data processing manager.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering in to such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
- Service providers who provide mobile number and/or email address validation services.
- Professional advisers, including lawyers, bankers,auditors and insurers based who provide legal, banking, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- We may share your Technical Data (specifically your IP address) with Amazon Web Services, Mailchimp, Google, HubSpot, Pipedrive,Leadfeeder, Microsoft, Stripe, Chargebee.