Integritetspolicy

Entry into force: 20.1.2024

We are glad that you are interested in our privacy policy. We take data protection seriously and respect your privacy. It is important to us that you feel safe when using MinPiiri services and that you receive up-to-date information about how we process your personal data.

MinPiiri is a platform service offered by Palbassador Oy. Natural persons registered in the service can use the benefits offered in the MinPiiri service offered by businesses and associations (”Company”) in the MinPiiri, participate in lotteries organised by the Companies or the MinPiiri service, read Company newsletters and recommend a Company to their own network.

Palbassador Oy (”Registrar”, ”we”) and the service providers responsible for the implementation and maintenance of the service and acting on the Registrar’s behalf process personal data of the users of the MinPiiri consumer application, representatives of Companies registered for the service, and visitors of the website of the MinPiiri service (MinPiiri.com, MinPiiri.fi) (”Website”).

In this privacy statement, the word ”MinPiiri services” refers together to the MinPiiri consumer application, management application and cash register application, as well as other services offered by Palbassador Oy to users and companies, such as the Website. The word ”User” or ”you” collectively refers to both already registered and potential users of MinPiiri services, including natural persons in the capacity of consumers as well as representatives authorised by Companies for MinPiiri services.

We are committed to protecting your personal rights and keeping your personal information safe. We process your data legally, fairly, confidentially, securely and transparently. The purpose of this privacy policy is to help you understand what data we collect about you, why we collect it, how we process your personal data and how you can exercise your rights as a registered user. We are constantly developing and improving our services; this privacy statement can also be updated, if necessary, to correspond to changes in our data processing practices or other changes. If significant changes are made to the privacy statement, we will notify you when required by applicable law. You can find an up-to-date version of this privacy statement on the Website.

Some of our services may also be accompanied by a separate privacy statement; in that case we will publish it in connection with the service in question.

In all questions related to the processing of personal data and in situations related to the exercise of your own rights, we encourage you to contact the Registrar’s person responsible for data protection matters (see contact information in chapter 2).

Registrar

Palbassador Oy

Company ID: 2998621-3

Address: Metsonkaari 11, 90900 Kiiminki

Email: info@munpiiri.fi

Contact information for data protection matters

The person responsible for the data protection matters of the registrar can be reached by sending an email to the address privacy@munpiiri.com

Processed personal data and data sources

User information

User data is data that is collected either directly from you or, if you are an authorised representative of a Company, from the Company on whose behalf you use MinPiiri services. User data can be collected in different ways, for example when the User registers for the MinPiiri service, when the User updates his/her data through the functionalities of the MinPiiri applications, when the Company enters into a service contract with us, when the User subscribes to our newsletter or fills out a form on our Website.

Necessary user information to use MinPiiri applications:

When you register for the MinPiiri service as a natural person or as a Company representative and create a user account, you must give us your full name and email address and choose a password for the service.

User information you voluntarily give when using MinPiiri services: We strive to improve your user experience with the following voluntarily provided information:

Additional account information (natural person and Company representative):

Phone number
Other information you give us when creating a user account, as well as information you give us later when you edit your user/account profile.
Additional account information (natural person only):
Profile picture
Location data (if you consent to the processing of your location data).
Other information and files you voluntarily provide (natural person and Company representative):
Marketing consents and prohibitions
Information that you provide about yourself when dealing with us through our customer service by phone, email or via instant messaging services, or that you send to us through the online forms on the Website or the message service of the MinPiiri application
The image files you download and register yourself through the MinPiiri service, for example in connection with the service’s recommendation functionality.
Other information and files you voluntarily provide (natural person only):
your favorite shops and other preferences in MinPiiri applications.

If you are a representative of a Company, in addition to the user data collected from you and the Company you represent, we may process personal data we receive through a third-party service provider. This includes, among other things, the processing of the Company’s contact person’s data to enable communication, marketing and managing customer relations. We primarily collect such information directly from the Companies themselves or from other public sources of information, such as local trade registers or companies providing the relevant information services.

Usage information

Usage data is generated from your interaction with MinPiiri services. The purpose of collecting data is to analyse and develop the MinPiiri service, so that it serves you even better in the future, and to use the information in the statistical monitoring of the number of visitors and the use of functions of the MinPiiri service, as well as in various other measurements.

As a rule, we do not use user data to identify you as an individual. However, if you can be identified from them either alone or combined with user data, we will also process your usage data as personal data.

We can automatically collect the following usage data when you use MinPiiri services as a natural person or as a representative of a Company:

Information and identifiers that describe your device or its operating system, your browser or the MinPiiri application, their versions, features and settings
Information and identifiers about your carrier, Internet service provider and network connection type, including your IP address
Identifiers provided by your device or third parties to application providers or advertisers, or identifiers created by us
Information that your browser sends when you use MinPiiri services
Country, region, time zone and IP geolocation information
Where you followed a link to MinPiiri services and links you followed from MinPiiri services
Information about your interaction with the MinPiiri services and their use, including, for example, what features of the MinPiiri service you use and what content you see or use in it. In the case of a natural person, this may cover, for example, the benefits you use in the MinPiiri consumer application and the related time and place information, lottery participation, information related to the registration of your referrals, and messages sent to Users through the service. We may also collect various analytics and diagnostic information about your behavior, for example when, how often and for how long you visit our services and its different views or features. See also the section ”Cookies and analytics” below. In the case of Company representatives, we can collect information about when and what kind of Company content you configure, edit or delete in connection with the Company’s account or to/from the MinPiiri service to be offered to consumer users, and when and for what purposes you use the checkout application of the MinPiiri service.

Cookies and analytics

We may use various technologies to collect and store usage data when Users visit MinPiiri services. These technologies may include, but are not limited to, cookies, website data storage, and the use of web and application analytics or telemetry.

A cookie is a text file that our server stores on the User’s hard drive or in the memory of the mobile device. The cookies and other information on the Website that we use do not harm your device or your files. With the help of cookies and other information stored on your device, we can identify the visitors of MinPiiri services, speed up and facilitate the use of the service, and create summarising information about our visitors. This helps us develop MinPiiri services and serve you better. We can also use cookies or other technologies to tailor the MinPiiri service and the content we offer to your individual interests. The storage time of different cookies can vary from less than a minute to permanent or until the cookie in question is deleted.

If you leave a comment on the site, you can choose to save the name, email address and url address in a cookie. This function increases the convenience of use, because you don’t have to fill out the form again every time you add a comment. Cookie information is deleted from the browser after one year. If you have an account and log in to the site, we set a temporary cookie that determines whether your browser supports cookies or not. This cookie does not contain personal information and is deleted when the browser window is closed.

You can manage cookies via the cookie settings (Website cookie banner). With the exception of essential cookies, you can give your separate consent to all other cookies (marketing cookies and analytics cookies). Please note that if you deny the use of cookies, some parts of the MinPiiri service may not work properly.

MinPiiri services may use pseudonymized identifiers or the tools and services listed below provided by a third party and integrated into our software:

Name: Google Analytics

Service Provider: Google

Purpose of use: Visitor and usage data analytics

Service provider’s Privacy Statement: Link (https://policies.google.com/terms?hl=fi)

We use the tools and services mentioned above to develop the MinPiiri service and to improve the user experience. We strive to use the above-mentioned services while respecting your privacy, for example by pseudonymization of the IP addresses and other personal identification data collected by them and by removing the permission given to the service providers to use the collected data as far as possible.

Purposes and grounds of processing

We process personal data only to the extent that it is necessary and appropriate in terms of the processing purpose associated with the personal data. One or more of the following processing purposes may apply to the processing.

Agreement: We process your personal data to the extent necessary to fulfil our contractual obligations to you or a Company

to offer MinPiiri services and content to consumers in accordance with our terms of use agreement and to offer MinPiiri services to Companies in accordance with the service and terms of use agreements between the Company and Palbassador Oy;
to notify you of significant changes to terms, privacy policies, and other agreements.

Consent: For natural persons, we can process your personal data based on consent, for example

when we send you electronic marketing messages or newsletters based on your consent;
when you win a lottery, to hand over your contact information to the company awarding the prize in order to announce the win;
when processing your location data;
when processing information collected from the Website with the help of cookies in relation to your preferences, statistics / analytics or marketing, or for example when targeting you with advertising on the Website.

Legitimate interest: We can process your personal data if there is an appropriate and justified interest (i.e. a legitimate interest) for conducting, maintaining and developing business or creating and maintaining customer relationships. When we process personal data based on a legitimate interest, we always weigh the benefits of the processing and the potential harm to the User. We also minimise identifying personal information. You have the right to object to processing based on a legitimate interest. We can process your data based on a legitimate interest, for example

for data, system and network security and to prevent and investigate misuse and fraud of our services; for example, the referrals registered by the User through the MinPiiri service and related visual materials are available to the Registrar to detect possible abuses;
for claims processing and collection and legal processes;
when we contact you to inform you about matters related to your use of the MinPiiri service or to notify you of significant changes related to MinPiiri services or software update needs;
to request a review or user/customer feedback regarding MinPiiri services;
to answer your questions or resolve your customer support case if you contact us;
to investigate and resolve possible malfunctions and error situations related to your user account;
to tailor or target the content of the MinPiiri services to match your preferences;
regarding Company representatives, when making new contacts related to ordering the MinPiiri service and approaching new potential customers through direct marketing, taking into account their likely interests;
in our product development and development of our services: we process usage data collected from several Users anonymously and statistically in order to improve the quality, content and usability of MinPiiri services and to develop our business and service, for example by analysing statistics, trends and usability related to the use of MinPiiri services and its various functionalities.

Legal obligation: We may process your personal data to fulfil our legal obligations. This includes information that is processed to comply with our accounting obligations and to provide information to relevant authorities, such as tax or law enforcement authorities, in accordance with our legal obligations.

Automatic decision making

When processing your personal data in order to provide the MinPiiri service to you and for other purposes mentioned above, we may use automatic means and technical solutions in the processing. However, automated processing has no legal effects or other significant effects on the data subject, and it is not considered automatic decision-making.

Transfer to countries outside Europe

Personal data collected through the MinPiiri services is primarily stored and processed in EU/EEA countries or in a third country where the European Commission considers that there is an adequate level of protection. However, we or our service providers may in the future transfer your personal data or process it in countries outside the European Economic Area. In that case, we will inform you separately in our privacy policy.

We ensure appropriate protection for the transfer of personal data to countries outside the European Economic Area through contracts concluded with our service providers (such as the European Commission’s model contract clauses) or other appropriate protective measures.

Disclosure of personal data

Your personal data will be shared within the Registrar’s organisation only if and to the extent that it is reasonably necessary for the purposes stated in this Privacy Policy.

We value your privacy. In principle, we do not allow Companies to access your personal data collected through MinPiiri services, but Companies process User data anonymously in order to statistically monitor and analyse Company-specific service-related usage data. We will not share your personal data with third parties outside the Registrar’s organisation unless one of the following conditions is met:

Technical and maintenance reasons related to the provision of the MinPiiri service: We can hand over access to your personal data to a limited and carefully considered group of representatives of our own cooperation / service provider partner organisations, who are responsible for the technical implementation and maintenance of our service. The transfer of data in question is done to maintain and develop the functionality and quality of our service’s features and to investigate possible technical error situations. We ensure with appropriate measures and agreements with our service provider partners that the Users’ personal data receives adequate protection in these cases.
Winning in a lottery organised by a Company: In the MinPiiri service, the User can participate in lotteries organised by Companies. We pass on the name and contact information of the winners of the lottery to the company organising the lottery. This disclosure of information is done with the User’s separate consent, which is requested when participating in the lottery.
Legal Reasons and Processes: We may share your Personal Information with outside third parties if we determine that disclosure and use of the Personal Information is reasonably necessary to comply with any applicable law, regulation and/or court order;
to detect, prevent or otherwise deal with fraud, crime, security issues or technical problems;
within the limits permitted by law, to protect the interests, property or safety of the Registrar, Companies, Users or others.

We will notify you of such disclosure and processing of personal data within the realm of possibility.

Cases of abuse: If the User clearly abuses the MinPiiri service or acts contrary to its terms of use and in this way causes damage to a Company, the User’s user data and the usage data related to the Company can be handed over to that Company for the investigation of the case of abuse. Also, the referral coupons registered by the User through the MinPiiri service and related images uploaded by the User can, in clear cases of misuse, be handed over to the Company related to the referral in order to investigate the possible damage caused to the Company by the misuse. The necessity of data transfer in cases of abuse is assessed on a case-by-case basis, and the aim is to inform the User about the transfer.
Other justified reason: If the Registrar is involved in a business transaction, merger, or other asset sale, we may transfer your personal data to the third party in question. We will notify all concerned Users if personal data will be transferred to another company in this way or if a different privacy policy is applied to them.
With your consent: In some cases, we can share your personal data with third parties outside of the Registrar with your separate consent. You have the right to withdraw this consent at any time, free of charge, by contacting us or by using the functionality provided by MinPiiri applications, the Website or other communication methods we provide to withdraw consent.

Please note that if you hand over personal data directly to a third party, for example through an external link in MinPiiri services, the processing of the data is typically based on the terms and policies of the third party in question.

Data retention period

We keep your personal data for as long as it is needed for the purposes presented in this Privacy Statement for which your data was collected and processed, or as required by laws and regulations. The retention period may depend on the nature of the data and the purposes of the processing.

When the User has deleted his/her user account or the user account has been deleted by the Registrar, personal data can only be stored as long as the law requires it or it is reasonably necessary in terms of our legal obligations or our legitimate interests, such as processing claims, accounting or internal reporting. However, personal data is always deleted from our system no later than 2 years after the deletion of the user account. Usage data collected from the user may remain anonymous and unidentifiable in the system after the user account is deleted due to the collection of general usage statistics of the service.

Information security

We use appropriate technical, physical and organisational security measures to protect all information in our possession against loss, destruction, misuse and unauthorised access, unnecessary disclosure and unauthorised modification.

All personal data we collect is treated confidentially. Information in electronic form is stored in information systems that use a personal username and password for authentication, which are only disclosed to persons employed by the Registrar and service provider partners acting on its behalf. The employees of the Registrar and its service provider partner organisations have the right to access the data stored in the registry only when their work requires it.

Your rights

You have the right to receive information about the processing of your personal data. A summary of the processing of personal data can be found in this privacy statement.

You have the right to access your personal data in our possession. You can view certain information directly through your MinPiiri service user account or request a copy of your personal information by contacting us.

You have the right to correct your information. If the information collected about you is incorrect or incomplete, you have the right to have the information corrected or supplemented. You also have the right to ask us to delete your outdated personal data. You can correct or update some of your personal data directly through your MinPiiri service user account. You can also contact us directly to correct the information.

You have the right to withdraw consent. If the processing is based on your consent, you can withdraw your consent at any time free of charge. Withdrawal of consent may lead to a reduction in the possibilities of using MinPiiri services. Withdrawal of consent does not affect the legality of processing carried out on the basis of consent prior to its withdrawal.

You have the right to request the deletion of your data and to be forgotten. We will comply with such a request unless we have a legal basis not to delete the data.

You have the right to restrict the processing of your data. You can ask us to limit the processing of personal data, for example when

requests for deletion, correction or objection to your data are pending and/or when we have no legal grounds to process your data;
the processing is illegal, but you do not request the deletion of the data;
The Registrar no longer needs personal data for the original purposes of the processing, but you need them for legal purposes.

Limiting the processing of data may lead to a reduction in the possibilities of using MinPiiri services.

You have the right to object to the processing of your data. You can always object to the processing of your personal data if the processing is based on the legitimate interest of the Registrar. If you object to the processing of your personal data, it may lead to a decrease in the possibilities of using MinPiiri services.

The right to data portability. You have the right to receive the personal data you have provided to us in a machine-readable format and to transfer this data independently to a third party.

Not all of these rights can be used in all situations, depending on, for example, the grounds for personal data processing. Your request to exercise your rights will be evaluated based on the circumstances of the individual case. Please note that we may also retain and use your information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

How to exercise your rights

The above-mentioned rights can be exercised by contacting the person responsible for data protection issues of the MinPiiri service by sending an email to the address privacy@MinPiiri.com, including the following information: full name, address, email address and phone number. After receiving your message, we may ask you for additional information or additional steps to verify your identity. We handle your personal data very carefully and cannot share or change your personal data without confirming your identity. We may refuse or charge for requests that are unreasonably frequent, excessive or clearly unfounded.

Direct marketing

We always ask for your consent for electronic direct marketing purposes. You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling for direct marketing purposes by using the functions related to granting / denying consent on the Website or the MinPiiri service, by contacting us at the addresses mentioned above or by using the option to cancel the messages presented in connection with direct marketing messages.

How to contact the Data Protection Ombudsman?

If you consider that our processing of personal data is in conflict with the applicable data protection laws, you have the right to file a complaint with the local data protection authority in Finland, the data protection officer. The supervisory authority’s contact information is:

Office of the Data Protection Ombudsman

Visiting Address: Lintulahdenkuja 4, 00530 Helsinki

Postal address: PL 800, 00531 Helsinki

Switchboard: 029 566 6700

Registry: 029 566 6768

tietosuoja(at)om.fi