Privacy Policy

1 GENERAL INFORMATION AND DISCLAIMER

The use of the websites of MultiTaction Ltd (www.multitaction.com, www.cornerstone.fi and other sites belonging to the multitaction.com domain) (hereinafter referred to as the “Websites”), offered by MultiTaction Ltd, a company duly incorporated pursuant to the laws of Finland, with registered office at Henry Fordin katu 6B, 00150 Helsinki, Finland, assigned Finnish Tax VAT ID FI-21268145 (hereinafter referred to as “MultiTaction”), implies in all cases the collection of certain information about its customers and service users.

This Privacy Policy is applicable to all customers, users, data subjects and/or other persons who contact MultiTaction for any reason and who access the Websites (hereinafter referred to as the ”Web users”).

This Privacy Policy contains a detailed description of the following: (i) the data collected about MultiTaction customers and their employees, (ii) the purpose of processing such information and (iii) how the use of such information can be governed and controlled by MultiTaction.

This Privacy Policy is applicable to all services offered on the Websites, along with any pages or services that could be added to the Websites in the future, and it is subject to the terms and conditions set out in the applicable regulations on data protection and on information society services and electronic commerce.

This privacy policy update meets the obligations of EU General Data Protection Regulation (GDPR).

2 CONTROLLER

Unless stated otherwise, MultiTaction is the controller of the personal data collected by means of these Websites.

For any query, request or clarification regarding the processing of your personal data, you may contact the email and post addresses provided as follows: Multitaction Ltd, Henry Fordin katu 6 B, 00150 Helsinki; or personaldata@multitaction.com.

3 THE PERSONAL DATA SUBJECT TO PROCESSING

For the purpose of rendering the services offered, MultiTaction will process the following personal data:

  • Any initial data you voluntarily provide to us in your application to be registered as a user of the Websites, your request for information from our company, your request to subscribe to our newsletters or your request to obtain the services offered by MultiTaction. In each form, we will clearly and precisely specify which data you must provide on a mandatory basis to proceed with the application, request or service request you submit to us from time to time.

  • Any data that are generated or exchanged with you after your initial application in order to fulfil such initial application.

  • Any data generated in relation with the use of the Websites by using cookies and information from the log file, including the IP address, the kind of browser, the URLs, the number of clicks and the way in which the User interacts with links, domain names, landing pages and pages visited.

  • Any personal data you provide through a social network for the purpose of managing your application. These data depend on the privacy settings of each user, the use each user makes of the social network and the own privacy policies of the social network in question.

The Web Users guarantee the authenticity and truthfulness of all data provided through the Websites and must update any information provided to MultiTaction so that it matches the real and current situation at all times. The Web Users shall be held liable for any false or inaccurate statement and any damages this may cause to MultiTaction or any third parties.

MultiTaction shall manage the data collected pursuant to the applicable laws and in accordance with the terms and conditions set out in this Privacy Policy.

4 USE OF PERSONAL DATA

The personal data provided to MultiTaction will be used to process and manage requests made by the Web Users to MultiTaction at any time, regardless of whether these are for information, registration or obtaining the services offered by the company. MultiTaction may also use personal data for the following purposes:

  • Managing and controlling the Web Users’ transactions and offering services to them through the Websites, email, telephone, and other means of communication

  • managing and controlling compliance by the Web Users with the terms and conditions of our Websites and their accounts,

  • managing and controlling their user account on the Websites,

  • sending, including by electronic means, promotional information about the products and services offered by MultiTaction similar to those included in the requests received from its customers and/or Web Users.

  • only where you EXPRESSLY CONSENT to this, sending notices and information, including by electronic means, about promotional offers related to the goods and services marketed or offered by MultiTaction’s partners or collaborating companies or by any third party, providing such information relates to services similar or related to those rendered by MultiTaction.

5 AUTHORISATION FOR THE DATA PROCESSING

MultiTaction is authorised to process your data for the purpose of managing and processing requests by Web Users as this is necessary for MultiTaction to fulfil its contractual obligations in relation with such requests.

Regarding the dispatch of promotional information about products and services similar in nature to those requested or purchased by the Web Users, such processing is in the legitimate interest of MultiTaction, which is expressly acknowledged by the data protection regulations and is expressly authorised in the regulations on information society services. Web Users may, now or at any other time, object to receiving commercial notices about MultiTaction’s products and services by sending an email message to personaldata@MultiTaction.com.

Promotional information about products and services offered by partners, collaborating companies or third parties, which relate to services that are similar or related to those rendered by MultiTaction, will only be sent if you have EXPRESSLY CONSENTED to such processing. If you consent to receiving such notices, your consent includes for our company to create a personal profile about you in order to send you customised information about products and/or services tailored to such profile. The personal profile will be created based on the preferences you communicate to us throughout your relationship with MultiTaction, your different interactions and exchanges of information with our company and the information available on the Internet and social networks in accordance with your privacy settings.

The processing of your personal data for the purpose of sending promotional notices about the aforementioned products and services offered by third parties is authorised by the most recent consent granted by you. If you would like us to stop sending you these kinds of notices, you may revoke your consent at any time by sending a request for the attention of the Data Protection Officer to the specified post or email addresses. Such revocation shall not affect the lawfulness of the processing carried out prior to the revocation and may mean that MultiTaction will be unable to process or fulfil your request or that that request is affected by such revocation.

6 DATA DISCLOSURES, INTERNATIONAL TRANSFERS AND AUTOMATED DECISION-MAKING

MultiTaction does not disclose data to third parties without first obtaining your consent, except where necessary to fulfil the legal and contractual obligations to which MultiTaction is subject at any time due to its nature and business.

In this respect, MultiTaction hereby informs you that your data may be disclosed to service providers with whom MultiTaction has signed the relevant agreements pursuant to the applicable regulations.

MultiTaction uses services rendered by technology providers located in countries that do not have regulations equivalent to the European regulations. Its use of these services meets all the requirements set by the data protection regulations, with the guarantees and safeguards required to protect your privacy being applied to transfers of your data.

For more information about how your privacy is guaranteed, you may contact the Data Protection Officer through the specified post and email addresses.

MultiTaction does not adopt any decisions that could affect you in a significant manner based solely on automated processing of your data. All decision-making processes of our company related to your requests, services, queries or purchases are conducted with the involvement of a human being.

7 STORAGE PERIOD

The Web Users’ personal data will be kept for as long as their relationship with MultiTaction continues. After the relationship with the Web User has ended, MultiTaction will keep the Web User’s data for the legal statutes of limitations applicable to each processing, up to a maximum term of five (5) years after the relationship with the Web User has ended. In such case, the data will only be processed to demonstrate that we have fulfilled our legal or contractual obligations. Once such statutes of limitations have ended, their data will be deleted or, alternatively, anonymised.

8 SECURITY AND CONFIDENTIALITY MEASURES APPLIED TO THE DATA

MultiTaction has implemented and maintains administrative, technical and organisational measures appropriate to the kind of data it collects and subject to the terms and conditions set out in the applicable data protection regulations for the purpose of protecting the personal information provided to MultiTaction against unauthorised or unlawful access and accidental loss, damage, alteration or destruction of data. Only authorised staff may access the personal information and they may only do so for the permitted business purposes. Notwithstanding the foregoing, criminal acts may be committed by third parties even where MultiTaction uses all the means at its disposal to prevent such acts.

Despite this, the user is responsible for suitably protecting any codes and passwords provided for access and prevent them from being used or accessed by unauthorised third parties. MultiTaction cannot be held liable for any inappropriate use of the user name and password carried out by any user.

9 EXERCISING YOUR RIGHTS

You may exercise your rights to withdraw any consent you granted, to access, rectification, erasure, portability, restriction and/or objection to the processing of your personal data at any time and free of charge by sending a notice to our Data Protection Officer to the post and email addresses specified below: Multitaction Ltd, Henry Fordin katu 6 B, 00150 Helsinki; or personaldata@multitaction.com

MultiTaction may review this Privacy Policy at any time. The current Privacy Policy will be available on the Websites at all times. Any updates thereto shall come into force immediately upon being published, which will be notified to all Web Users.

10 ACCEPTANCE

By providing their personal data to MultiTaction and/or by registering as a user and/or using the Websites, the Web Users expressly accept that their personal data will be used for the purposes set out in this Privacy Policy, which include, inter alia, commercial notices and storage of their personal data.

11 APPLICABLE LAW AND COMPETENT JURISDICTION

The Websites and this Privacy Policy are governed by Finnish law. The parties expressly agree to submit any dispute arising from this Privacy Policy or any claim related to the contents and the services of the Websites to the courts of Helsinki (Finland), waiving any other jurisdiction to which they may be entitled. Date of validity: 25 May 2018