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KH Group plc’s privacy statement concerning website user

1. Controller

KH Group Plc

Pohjoisesplanadi 33

FI-00100 Helsinki, Finland

+358 40 500 6898 (switchboard)

info@khgroup.com.com

(hereinafter “we” or “KH Group”)

2. Contact person in matters related to the data file

Tiina Gröndahl

+358 40 846 0860

info@khgroup.com

3. Name of the data file

Privacy statement concerning website users

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

The processing of personal data is based on the company’s legitimate interest related to the execution of direct marketing and product development.

Personal data is processed for the following purposes:

• analysis and profiling of the behaviour of data subjects;
• targeting of advertising in our company’s proprietary online services and those of other parties.

We employ automated decision-making (including profiling) to identify data subjects’ personal profiles and online behaviour, among other things. This information is used for purposes such the development of our website.

5. What information do we process?

In connection with the privacy statement, we process the following information about the users of the website:

• data subject’s basic information, such as name and/or other unique identifier;
• data subject’s contact details, such as an e-mail address, telephone number, street address;
• information on companies and their contact persons, such as business identity code and names and contact details of contact persons;
• potential objections and consent to direct marketing;
• information related to the data subject’s behaviour in services and on websites that is intended for profiling purposes, such as visited sites and services, the duration of the visit/use, the actions carried out on the sites and in the services;
• technical information on the data subject’s terminal devices, such as IP address, MAC address and operating system;
• data submitted by the data subject to KH Group, such as online forms, online chat posts, profile information, feedback;
• any other information given on the website by the data subjects on themselves.
  
  6. Where do we receive the information from?

We receive the information primarily from the website and from the data subjects themselves.

Additionally, personal data may also be collected and updated for the purposes indicated in this Privacy Statement from other public sources and government agencies or other third parties in compliance with the applicable legislation.

Such collection and updating of data will be carried out manually or automatically.

7. Who do we disclose the data to and do we transfer the data to outside the EU or EEA?

We do not disclose the data to third parties.

We engage several subcontractors that process personal data on our behalf. We have outsourced the management of our IT systems to external service providers. The personal data is stored on the servers administered and protected by such service providers. We have concluded appropriate contracts on the processing of personal data with these subcontractors to protect your personal data.

We do not disclose personal data outside the EU/EEA.

8. How do we protect the data and how long will we retain it?

Access to the system containing personal data is limited to those of our employees who are entitled to process website visitor data in the course of their work duties. Each user has a unique username and password to access the system. The data is saved in databases protected by firewalls, passwords and other technical means. The databases and their back-up copies are located in locked rooms and can only be accessed by pre-designated individuals.

We retain personal data for as long as is necessary for the intended purpose of such data..  As a rule, we retain the data pertaining to website users for one (1) year from its collection.

We assess the need for the retention of the data on a regular basis with due regard to legal requirements. Additionally, we take other reasonable measures to ensure that the data file does not contain any information on data subjects that is inconsistent with the purposes of processing, or outdated or incorrect. We correct or erase all such data without delay.

9. How and for which purposes do we use cookies?

The website uses cookies for the provision and development of KH Group’s services, for enhancing the user experience of the website and for targeting marketing efforts.

A cookie is a text file that is send to, and stored on, the user’s own computer. Cookies do not damage users’ computers or files. Cookies can be used for collecting information such as the following: downloaded pages, browser type, operating system, date and time.

You may prevent the use of cookies in the browser’s settings. If you disable the feature, this may slow down certain services or entirely prevent access to certain web pages.

KH Group’s website uses the Google Analytics tool. The Google Analytics application uses cookies based on which statistics on the use of individual web pages can be compiled and the use of the site can be analysed. Cookies collect anonymous data on the website traffic. Such data cannot be linked to a specific person.

The data collected on the use of KH Group’s website (‘commercial cookies’) can also be used for the provision of advertising targeted at a specific browser. Target group segments are created from the data based on the websites specific browsers have visited during a specific period. Based on the target group segments, the user will be shown advertisements that will most likely interest them. Advertisers and advertisement networks target their advertising based on the behaviour data collected from KH Group’s web pages. You may prevent targeted advertising in its entirety or in detail through the YourOnlineChoices website (www.youronlinechoices.eu).

10. What are your rights as a data subject?

As a data subject, you have the right to access the data on you recorded in the personal data file and demand that any incorrect data be corrected or erased if legal grounds for this exist. You also have the right to cancel or modify your consent.

Under the General Data Protection Regulation (effective as of 25 May 2018), you as a data subject have the right to object to or restrict the processing of your data or lodge a complaint regarding the processing of personal data with a supervisory authority. Additionally, you have the right to receive your data from our system in a standardised format as specified in the General Data Protection Regulation.

For special personal reasons, you may also object to the profiling and other processing actions pertaining to you when the processing of the data is based on our legitimate interest. When filing such a request, you must specify the specific circumstance you wish to invoke as a basis for your objection. We may only refuse to comply with such an objection on the grounds set out in law.

As a data subject, you have the right, at any time and free of charge, to object to such processing, including profiling, insofar as it is related to direct marketing.

11. Who can you contact?

Any communications and requests related to this Privacy Statement should be addressed in writing or in person to the designated contacts person identified in section two (2) above.

12. Changes to this Privacy Statement

If we make any changes to this Privacy Statement, we will indicate them in an updated statement. If the changes are significant, we will also communicate them in other ways, such as by e-mail or by posting a notice on our website. We recommend to visit our website on a regular basis and take note of any changes made to our privacy statement.