Efecte Plc, our affiliates and subsidiaries (collectively “Efecte”, “we” or “us”) are committed to protecting the privacy of our customers and business partners as well as Website and Event visitors and registrants (collectively “Data Subjects” or “you”).
This Privacy Statement (the “Privacy Statement”) describes how we collect, receive, use, store, share, transfer, and process your information, that can be used to directly or indirectly identify you (the“Personal Data”). It also describes your choices regarding use, as well as your rights of access and correction of your Personal Data.
2 ABOUT US
Efecte offers cloud-based (Software as a Service, SaaS) service and identity management solutions, supported by professional services. They streamline and simplify management of services, IT systems and infrastructure in organizations. For more information about Efecte, visit our website at www.efecte.com.
This Privacy Statement applies to the information and data collected by Efecte as a controller, including the Personal Data collected (i) on our Websites, (ii) from Events, (iii) from the Services offered by Efecte or Partner, and (iv) through other channels as described below in this Privacy Statement.
Efecte may also act as a processor of your Personal Data in connection with the provision of the Services. When Efecte acts as the processor, Personal Data is processed in line with applicable data protection laws and data processing agreement entered into with the controller, where applicable. In such a case, please refer to the privacy policies of controllers for further information on the processing of Personal Data.
“Customer” means an individual or entity that purchases our Services.
“Event” means event registration or attendance information for events hosted by us or our business partners where we collect information from registrants and attendees.
"Customer Data" means the electronic data uploaded into the Services by or for Customer or its Users.
“Partner” means an entity that sells Efecte products and services or provides services or technology toEfecte’s customers. To see a full list of our Partners, please visit our website at www.efecte.com/our-partners.
“Services” means any cloud services, professional services, third-party services and trial based demo-services that Efecte provides to an individual or entity.
“User” means an individual authorized by the Customer or Partner to access and use the Service.
“Website” means all websites including, but not limited to www.efecte.com, www2.efecte.com, www.community.efecte.com and www.investors.efecte.com, that refer to this Privacy Statement.
5 HOW WE COLLECT INFORMATION
As further described below, we collect several types of Personal Data from and about you. The collected Personal Data broadly fall into the categories stated below in this section.
For clarity, Efecte does not collect sensitive information meaning special categories of Personal Data. Also the Websites, Events or Services are not intended for or targeted at children under 16 years, and we do not knowingly or intentionally collect Personal Data about children under 16 years.
5.1 Information you voluntarily provide to us
Efecte collects Personal Information from you, when:
- filling out forms on our Website (including and without limitation to name, position, employer, mailing address, email address, and telephone number).
- you post material to our Website, participate in bulletin boards, chat rooms, blogs, comment threads, forums, or other interactive features of our Website, register, or request further information or Services from us.
- you register to use Services.
- you enter a contest or promotion we sponsor.
you report a problem or request support with our Website, Event or Services.
you contact us.
you complete our surveys.
you register for or attend an Event.
you submit other information to us related to your use of our Website, Services or attendance to an Event, including without limitation, billing information.
5.2 Information we collect as you navigate through the Website
When you view content provided by us, we automatically collect Personal Information about your computerhardware and software. This information can include your IP-address, usage patterns, traffic data, location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system and browser type. We may also collect information about any transactions, that you enter into on the Websites or using the Services.
We also collect some of this information using cookies and similar tracking technologies. You can set your browser to reject all or some cookies, or to alert when websites set or access cookies. If Data Subjects choose to reject cookies, website and Services may still be used, however, the access to some functionality and areas of the website may become inaccessible or not function properly. The purpose of cookies used by on Websites or Services is to collect information about how you interact with our Website or Services and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this Website and other media.
5.3 Information we collect as you use Services:
Our Customers process Customer Data in the normal course of using our Services and which is not
governed by this Privacy Statement. We also collect several types of information from our Customers, including:
- General information, including a Customer or Partner’s company name, business-ID, address, billing information and the Customer or Partner representative’s contact information.
- Quantitative data derived from our Customers' and Users' use of the Services, for example, and without limitation, the number of active roles within a Customer’s instance.
- Information and correspondence about our Customers and Users submitted by or to us in connection with Services or other requests related to our Service.
- Server logs to develop and support the Services.
5.4 Information from third-parties or other sources
We may collect and use information we receive about you from third parties in connection with your use of the Website, Services or attendance to an Event. For instance, we may receive information about you from our Partners related to your registration information for Events. We also use third parties for reporting and analytics to measure the effectiveness of our Website and marketing efforts, and to identify areas for improvement.
We may also receive information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, information that we acquire from service providers or information that we may acquire from other public registers or sources. We may combine information we collect from third parties with information you provide us to update, expand or provide you with tailored information regarding our Services and Events.
Our Websites provide links to other websites of third parties. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Statement does not apply to these other websites, which are subject to any privacy and other policies they may have.
6 HOW WE USE INFORMATION WE COLLECT
Efecte uses Personal Data of Data Subjects in compliance with this Privacy Statement to manage our websites, host Events, manage our business relationships, and to offer the Services. In this context, Personal Data may be used for:
- market and customer analysis;
- reporting and statistical purposes;
- marketing purposes such as product suggestions, offers and customised marketing based on Data Subjects profile and preferences;
- direct marketing, including, where applicable direct marketing by electronic means unless objected by the Data Subject;
- improving the browsing experience by personalizing the Websites;
- developing and improving our Services;
- administration notices, invoicing and account management;
- database management and maintenance; and to meet legal requirements, including and not limited to corporate, accounting and securities market-related requirements.
Efecte may also share Personal Data with Efecte’s trusted Partners, who act as processors of Efecte. Our Partners may use Personal Data:
- to contact you directly for marketing and/or direct marketing purposes, if you reside in a geographic are, where Efecte is not present or contacting you directly is otherwise justifiable;
- for market and customer analysis;
- for reporting and statistical purposes;
- for marketing purposes such as product suggestions, offers and customised marketing based on Data Subjects profile and preferences; and
- for direct marketing, including, where applicable direct marketing by electronic means unless objected by the Data Subject.
7 LEGAL BASIS FOR USING PERSONAL DATA
Efecte uses Personal Data on the following basis:
- for the performance of the contract between Efecte and the Data Subject (Article 6.1(b) of the GDPR);
- to comply with legal obligations applicable to Efecte (Article 6(c) of the GDPR, such as corporate and accounting; and
- for the purposes of Efecte’s or our Partner’s legitimate interests related to the business relationships between Efecte and the Data Subjects (Article 6(f) of the GDPR).
We will normally collect Personal Data from you only when we have your consent to do so. When we base the processing of your Personal Data on our legitimate interest (which is not overridden by your data protection interests or fundamental rights and freedoms) this is done to operate and administer our Websites, enable you to access and use the Websites and the Services as well as to send promotional communications. In these cases our legitimate interest is based on freedom of research, freedom of trade or mandatory legislation and our legitimate interest is not overridden by your data protection interests or fundamental rights and freedoms.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided in the "Contact Information” section below.
8 HOW WE SHARE INFORMATION WE COLLECT
We may disclose and share Personal Data to the following categories of recipients.
- To our subsidiaries and affiliates, (including those located outside the European Economic Area and Switzerland) who will use it only for the purposes described in this Privacy Statement.
- To our trusted contractors and service providers to support our business or to provide services on our behalf. Please see below the list of third-parties, that may be involved in the processing of your Personal Data.
- To our trusted Partners who act as processors of Efecte to provide among others customised marketing, product suggestions, customised Services, offers, quotes and newsletters.
- To a potential buyer (and its agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case Personal Data held by us about you will be among the assets transferred to the buyer or acquirer.
- To any other person with your consent to
We do not sell, rent or trade information collected through the Website, Services or Events with third parties solely for their promotional purposes. All third-parties involved in the processing of Personal Data are required to maintain the confidentiality of your information.
If you have questions about or need further information concerning the involvement of our trusted third-parties in the processing of your Personal Data, please contact us using the contact details provided in the "Contact Information” section below.
9 INTERNATIONAL TRANSFER OF DATA
Personal Data is primarily not transferred outside the European Union and the European Economic Area (“EU/EEA”). If any such transfers are needed, they are performed subject to appropriate safeguards such as European Commission adequacy decision, other appropriate safeguards or standard data protection clauses adopted or otherwise approved by the EU Commission in accordance with the GDPR (“Standard Data Protection Clauses”).
Efecte has taken adequate technical and organisational measures in order to keep Personal Data safe and to secure it against unauthorised access, loss, misuse or alteration by third parties, such as encryption, access controls, and firewalls. However, data transmission over the internet is inherently insecure, and Efecte cannot guarantee that the security measures will prevent illegally and maliciously operating third parties from obtaining access to Personal Data and the absolute security of that data during its transmission or its storage on Efecte’s systems.
We evaluate the necessity and accuracy of the Personal Data on a regular basis. Efecte may retain the Data Subject’s Personal Data if we have a business need to do so or for as long as is needed to fulfill the purposes outlined in this Privacy Statement or for five 5 years from the Data Subject’s latest contact with us. Personal Data may also be, wholly or in part, retained for longer or shorter term if required by applicable law or if there is other justified reason to retain or delete them. In such a case, the Data Subject’s Personal Data shall be erased with no further delay after there is no longer any need for such a retention.
12 HOW TO ACCESS & CONTROL YOUR PERSONAL DATA
Data Subjects have a right to request:
- access to and rectification or erasure of their Personal Data;
- for restriction of processing concerning the Data Subject or to object to processing; and
- to receive, under certain preconditions, the Data Subject’s Personal Data in a structured, commonly used and machine-readable format and to transmit those data to another controller.
Data Subjects may exercise the aforementioned rights by sending a written request to Efecte. Where the processing is based on consent, the Data Subject has a right to withdraw such consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
In case the Data Subject considers that its rights under the data protection laws are infringed, the Data Subject may lodge a complaint with the supervisory authority of the Data Subject’s residence in the EU.
13 CONTACT INFORMATION
Data controller is:
Name: Efecte Oyj
Business ID: 1509667-4
Address: Säterinkatu 6, FI-02600 Espoo, Finland
All contacts and inquiries related to this Privacy Statement should be addressed to firstname.lastname@example.org