1 Who is the data controller

This is a data file shared by Framery Group (including Framery Oy and its subsidiaries). Framery Oy is the data controller. Contact details below:

Framery Oy, Business ID 2352713-9
Patamäenkatu 7, 33900 Tampere, Finland

2 Contact details regarding privacy issues

To contact our Data Protection Officer, email privacy@framery.com.

3 Data subjects and the content of the register

The data subjects are our current or past customers, prospects, and persons who have consented to receive marketing communication. The data we may collect are basic information (such as name, email, phone number, company, title, country, and city), information relating to the customer relationship (such as information on orders, delivery addresses, and billing information), behavioral information (including information collected using cookies and other such technologies), and other Analytics Data.

Analytics Data is data that accumulates from the User’s use of our online services. Analytics Data may sometimes identify a User when processed alone or combined with other data. When this is the case, we will treat Analytics Data as Personal Data. We may collect the following Analytics Data when the User visits or interacts with our online services:

• IP address
• Device and device identification number
• Browser type and version
• Internet service providers
• Date and time you used our services
• Sites visited and the session duration
• Internal user identification of the User if it is logged in to our services

4 Cookies

Framery tracks the behavior of the User with cookies. We use Google Analytics, Facebook Pixel, Leadfeeder, Hotjar, and Sentry to analyze this data.

Framery uses Facebook and LinkedIn services for online marketing. If a User who visits Framery’s website is logged in to their Facebook or LinkedIn accounts then this fact can be used for targeting ads of Framery’s products to the User when he/she uses these services.

Consent for using the cookies mentioned above is requested when the User enters the website for the first time. The User has the right to withdraw their consent at any given time. To review the status of your consent, change your consent or revoke your consent and see descriptions of the different cookies in use, please visit Cookie declaration page.

Framery uses Salesforce technology to provide the Framery 360 portal.

More information about the privacy of Google services is available here.

More information about the privacy of Facebook services is available here.

More information about the privacy of LinkedIn services is available here.

More information about the privacy of Hotjar is available here.

More information about the privacy of Leadfeeder is available here.

More information about the privacy of Salesforce is available here.

More information about the privacy of Sentry is available here.

5 Purpose of processing personal data

We collect and process your personal information for the following purposes:

Marketing

• Marketing communication
• Performing opinion surveys
• Arranging competitions

Customer management

• Delivering goods, services, and related invoices to you
• Providing customer support for sold goods or services
• Contacting you for contract management and for maintaining customer relationship
• Managing customer contact details

Business development

• Maintaining, developing, analysing, and keeping statistics on customer relationships
• Planning and developing our business operations

6 Legal grounds for the processing of personal data

Legitimate interest

We may rely on our legitimate interest to process your personal data for other marketing and business development purposes, provided that such interests are not overridden by your interests, fundamental rights, or freedoms. 

Contract

We need to process your personal information to fulfill customer orders and to provide services and support relating to Framery products.

7 Data sources

You	We primarily receive information directly from you when you contact us via email or our online forms.
Your employer organization	We may receive your information from your employer in connection with the business relationship between us and your employer.
Our partners	We may receive information regarding our end-customers from our partners.

8 Who has access (i.e. personal data processors)

Our subsidiaries	Some of your personal data may be accessible and processed by our subsidiaries.
Our authorized distributor partners	We may provide your personal information to our authorized distributor partners to assist you in acquiring our products.
Our service providers	We are using external service providers providing us, for example, marketing or email delivery services.

We ensure that all third parties are always bound by contracts, which sufficiently address data protection and confidentiality requirements. 

9 Transfer of personal data to third countries

We use international cloud services in the processing of personal data and data may be transferred outside the EU/EEA in connection with those services. Furthermore, if you or the company you are representing are located outside of EU or EEA, we may transfer your personal information to our local subsidiary or authorized distributor partner. 

If we do transfer personal data outside the EU or EEA, we will guarantee a sufficient level of data protection by, among other things, agreeing on matters related to confidentiality and processing as required by the legislation, e.g. by using model clauses adopted by the European Commission.

10 How long your information is stored

The retention period of your personal data depends on the information concerned and its purpose of use. We retain personal data for at least as long as they are needed for the execution of the purposes informed in this privacy notice. We regularly evaluate the necessity of data storage taking into account the applicable legislation. Additionally, we take reasonable measures to ensure that Personal Data that is incompatible, outdated or incorrect is not stored, but rectified or removed without delay.

11 How is your personal data protected

Framery uses different technical and organisational security measures in order to protect your Personal Data against unauthorised or unlawful processing, accidental loss or destruction, or damage in accordance with our internal security procedures covering the storage and destruction of Personal Data as well as access to Personal Data. Only the employees who need to process your personal data for the purposes mentioned above are entitled to access the system containing Personal Data. Each employee has a personal username and password to the system. The Personal Data is collected in databases that are protected by firewalls, passwords and other technical means.

12 Your rights

If you wish to use your rights, please contact our DPO via email. However, please note that not all of these rights can be exercised in all situations, depending on factors such as the basis for the processing of personal data.

 

Right of access 
You have the right to inspect your personal data we have stored in our register.

Right to request the rectification of data 
You have a right to request the rectification of inaccurate or incomplete personal data.

Right to request the erasure of data
You have a right to request the erasure of your personal data in certain cases (such as if the data is outdated or incorrect, or if the data processing is based on your consent).

Right to request the restriction of the processing of personal data and the right to object to the processing of personal data
You have a right to request the restriction of and to object to the processing of your personal data.

Right to withdraw consent regarding the processing of personal data
If the processing of personal data is based on your consent, you can at any time withdraw your consent regarding the processing of personal data.

Right to prohibit using personal data for the purposes of direct marketing
You have a right to prohibit using your personal data for the purposes of direct marketing and marketing or opinion surveys. Such prohibition may be given, for example, by unsubscribing from the mailing list according to the instructions provided in our marketing e-mails or by submitting a written request to the contact person of the register.

Right to prohibit profiling
You have a right at any time to prohibit using your personal data for the purposes of profiling.

Right to data portability
You may, subject to certain conditions prescribed by law, have the right to acquire your personal information in a machine-readable form and the right to transmit this data to another controller.

Right to lodge a complaint to the supervisory authority
You have the right to lodge a complaint concerning failures in the processing of personal data to the supervisory authority (Data Protection Ombudsman).

The California Consumer Privacy Act (CCPA) requires Framery to disclose if it sells Personal Data. Framery does not sell any Personal Data to third parties. Information of what data is processed and how it is processed among our online services is disclosed in this Privacy Notice.

In case you are a California resident, CCPA states that you still have the right to opt-out of Framery selling your Personal Data to external parties, in addition to disclosure and/or deletion of any of your Personal Data from Framery. Requests concerning the matter shall be delivered personally or in writing to the contact person referred to in section 2.