Combi Works Oy Ab, collect personal data of its customers and visitors of its websites whilst providing its services.
Combi Works processes the data with due care, in accordance with all applicable laws and regulations.
Our Privacy Statement explains what data we process, how we do that and how you may use your rights as a data subject (e.g. right to object, right of access).
This Privacy Statement constitutes a description of the data file of the users of our services and websites as set out in the General Data Protection Regulation of the European parliament and of the Council 2016/679 (GDPR)
This Privacy Statement may be updated from time to time. You can find the current version on our website. This Privacy Statement applies to all personal data that Combi Works processes during the execution of our services, including the personal data of visitors of the Combi Works websites.
This Privacy Statement only covers data processing carried out by Combi Works. The Privacy Statement does not address and we are not responsible for, the privacy practices of any third parties.
The controller of the processing of the personal information is: Name: Combi Works Oy Ab
Company ID in Finnish Trade Register: 1954585-2
Correspondence address: Mechelininkatu 6, 00100 Helsinki, Finland
E-mail address: email@example.com
Combi Works collects two types of information from our Users: (i) User Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify user´s representative as an individual, he/she can sometimes be recognized from it. In such situations, Technical Data can also be considered personal data under applicable laws.
As the clients (Users) of the Combi Works Platform are legal entities, we strive to operate with mainly with data not related to the natural persons, but to the User companies. However, as the legal entities – Users are represented by natural persons, we need to collect certain personal data about the representatives.
We may collect and process the following User Data about the Users and their representatives: (i) first and last name; (ii) place (company) of employment and job title, (iii) telephone number, (iv) e-mail address, (v) postal address and country of residence, (vi) date of birth, (vii) preferred language of correspondence; further, we collect on the User companies their: (iix) tax identifier, (ix) representation rights, (x) address and (xi) credit rating.
We may collect User Data from our Users, their representatives and visitors in a variety of ways, including, when they register to Combi Works Platform, subscribe to a newsletter or fill out a form. Further, please note that we also collect details of any transactions and payments Users carry out through Combi Works services. We will collect User Data from Users and visitors only if they voluntarily submit such information to us or carry out transactions or payments through our services or sites.
We and/or our authorized third-party service providers, may automatically collect Technical Data when you visit or interact with our services or sites. Technical Data may include the browser name, the type of computer or device, time spent on website, interaction with the Services, URL of the website you visited before and after visiting the Services, the time and date of user visits, surfing habits, IP address, operating system and the Internet service providers utilized and other similar technical information.
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There are several purposes of the processing of your personal data by Combi Works:
To provide our services and carry out our agreement with the Users
Combi Works processes personal data in the first place to be able to deliver our services to the Users and to run, maintain and develop our businesses. We use the data for example to handle Users´ payments or any refunds (where applicable) and to provide our Customers and Factories with the information necessary for the delivery of Orders. If you contact our customer service, we will use the information provided by you to answer your questions or solve your complaint. In order to ensure that our services are in line with your needs, these data can be used for things like customer satisfaction surveys. We might also request another party to do this for us.
For customer communication (including marketing)
Combi Works processes personal data to contact the Users regarding our services and to inform the Users of changes to our services and products. User data are also used for research and analysis to improve our services and our websites. We may also use personal data entered on our websites in certain cases to send information by e-mail about other services of Combi Works to the Users´ representatives, provided that representatives have given us consent to that.
For quality improvement and trend analysis
We may also process information about use of the services to improve the quality of our services e.g. by analysing any trends in the use of our services. When possible, we will do this using only aggregated, non-personally (by user or by user representative) identifiable data.
Legitimate grounds for processing
Combi Works processes personal data to perform our contractual obligations towards the Users and to comply with legal obligations. Furthermore, we process the personal data to pursue our legitimate interest to maintain and develop our businesses.
Combi Works may transfer personal data to countries outside the European Union and the European Economic Area. When we transfer any data to a country for which no adequacy decision of the European Commission exits, such transfer will be strictly on the basis of a written agreement and subject to the provisions of the (standard or other) clauses adopted by the European Commission. If you wish to know more about international transfers of your personal data, you may contact us via the contact details given in the Terms of Service.
We only share personal data within the organisation of Combi Works if and as far as reasonably necessary to perform and develop our services, e.g. with our customer service and marketing employees.
We do not share personal data with third parties outside of Combi Works unless one of the following circumstances applies:
It is necessary for the purposes of this Privacy Statement
To the extent that third parties (such as the counterparties in the Purchase Agreements and logistics operators who deliver the Order) need access to personal data to perform such services, Combi Works has taken the appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Statement and in accordance with all applicable laws and regulations. Furthermore, we may provide personal data to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in accordance with our Privacy Statement and any other appropriate obligations of confidentiality and security measures.
For legal reasons
We may share personal data with third parties outside Combi Works 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 Combi Works, our users or the public as far as in accordance with the law. When possible, we will inform Users about such processing.
For other legitimate reasons
With subject´s explicit consent
We may share your personal data with third parties outside Combi Works for other reasons than the one mentions before, when we have the subject´s explicit consent to do so, unless such is necessary for the provisions of our services (such as sharing with the counterparty of a Purchase Agreement or Order concluded through Combi Works Platform). You have the right to withdraw this consent at all times.
Combi Works does not store personal data longer than is legally permitted and necessary for the purposes for which the data were collected. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use. In general, we store data for the provision of services for a maximum of two years after our relation ended. Whenever the registered representative of the User is changed, personal data of the previous representative is erased from Combi Works.
Right to access
Combi Works offers to the representatives of Users access to the personal data we process. This means you as a subject of data processing can contact us asking us to inform you about your personal data that we have collected and processed and the purposes such data are used for. We may charge a processing fee in case less than 12 months have passed since your last data request.
Right to correct
You have the right to have incorrect/unprecise, incomplete, outdated, or unnecessary personal data we have stored about you corrected or completed by contacting us.
Right to deletion
You may also ask us to delete your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data. After the data have been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems.
Right to object
You may object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of our services or for compliance with a legal obligation. You may also object any further processing of your personal data after prior given consent. If you object to the further processing of your personal data, this may lead to fewer possibilities to use our websites and other services.
You may opt in to receiving electronic direct marketing communications from us, and allow us to use your personal data for direct marketing purposes, market research and profiling by clicking on the opt-in link provided in the Combi Works User profile.
Right to restriction of processing
You may request us to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may lead to fewer possibilities to use our websites and other services.
Right to data portability
You have the right to receive your personal data from us in a structured, commonly used format in order to transmit the data to another controller.
How to use your rights
You may use these rights by sending a letter or e-mail, including your name, address, phone number and a copy of a valid ID to us on the addresses set out above. If your request regards personal data in a cookie, you have to enclose a copy of the said cookie. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded. In case you consider our processing activities of your personal data to be inconsistent with the applicable data protection laws, you have a right to lodge a complaint with a supervisory authority (the Finnish Data Protection Ombudsman, Tietosuojavaltuutettu, www.tietosuoja.fi).
We will take all reasonable, appropriate security measures to protect Combi Works and our Users and their representatives from unauthorised access to or unauthorised alteration, disclosure or destruction of personal data we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should despite of the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you about the breach as soon as reasonably possible.
Our Privacy Statement applies worldwide, to all of the services offered by Combi Works. This Privacy Statement is published in English. Our Privacy Statement may change from time to time. You can find the current version on our website combiworks.com. We will not make substantial changes to this Privacy Statement or reduce your rights under this Privacy Statement without providing you with a notice.