Privacy policy

Custobar Oy (‘Custobar’ or ‘we’) collects personal data from its customers, users and visitors to its websites and services. In order to use the Services, you must register with Custobar by providing your contact information or by using a Customer Agreement. Some features and services may require you to provide additional information, but this will be clearly labelled, and you will be asked to provide the additional information before you can use those particular features and services.

This Privacy Policy governs the principles of storage and processing of personal data contained in the register and data processing when visiting our website. It provides information on what data we process, how we do this and how you can exercise your rights as a data subject (e.g. right to object, right to information). This Privacy Policy may be updated from time to time as necessary to reflect changes in data processing practices or otherwise. The current version can be found on our website at https://www.custobar.com/privacy/. Please note that this Privacy Policy only applies to the processing of personal data where Custobar acts as a data controller. The Privacy Policy does not address the privacy practices of third parties, for which we are not responsible.

Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is

Custobar Oy
Wonderland Work
Konepajankuja 1
00510 Helsinki Finland
Company ID: 2645106-1
Contact person: Laura Ek (info@custobar.com)
Telephone number: +358 50 3859915

Name of the register

Customer and Marketing Register of Custobar Oy (the ‘Register’).

Purpose of the processing of personal data

There are several purposes for the processing of your personal data by Custobar: To provide our services: Custobar processes your personal data primarily to be able to provide you with our services and to run, maintain and develop our business. We would like to know who you are so that we can tailor our services as closely as possible to your needs and wishes. Some of the features and services will not work fully if we do not know who is using them. If you contact our customer service, we will use the information you provide to answer your questions or deal with your complaint. To ensure that our services meet your needs, this data may be used for customer satisfaction surveys, for example. We may also ask another external party to do this for us.

For customer communication (including marketing), Custobar processes your personal data to contact you about our services and to inform you of any changes. Your data will also be used for research and analysis purposes to improve our services.We may also use your data entered in our Services in certain cases to send information and marketing communications by email, provided you have given us your consent to do so or for other legitimate reasons for such marketing communications.

Third party service providers: We may share your information with third parties who provide services to us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service and marketing support.Marketing communications:With your consent or with the ability for you to withdraw your consent, we may share your information with third parties for marketing purposes to the extent permitted by law.

Legitimate grounds for restricting processing and storage: Custobar processes your personal data in order to fulfil contractual obligations to you and to comply with legal obligations. In addition, we process your personal data to pursue our legitimate interest in maintaining and developing our business.

Legal bases

Data erasure and storage duration

We only store personal data for as long as is necessary for the purposes set out in this Privacy Policy. As soon as the legal basis for their processing no longer applies, we delete or anonymise them as quickly as possible. In some cases, however, legal bases may exist in parallel or a new legal basis may apply when a legal basis ceases to exist, such as the obligation to store certain data to fulfil a statutory retention obligation.

Processed data and data sources

Custobar collects two types of information from our customers: (i) Customer Data; and (ii) Technical Data. Although we do not normally use Technical Data to identify you as an individual, you may sometimes be recognised by it.In such situations, Technical Data may also be considered personal data under applicable law.

We may collect and store the following basic customer data in the register: (i) first and last name; (ii) e-mail address, telephone number, address and company; (iii) payment information and transaction data. In addition, we may collect the following customer relationship data: (i) customer relationship maintenance information; (ii) marketing authorisation information; and (iii) customer service data.

We may collect customer data from our customers and visitors in a variety of ways, including when they register for our services, when they submit customer feedback, claims or other communications, or when they subscribe to a newsletter or fill out a form. Please also note that we also collect details of any transactions and payments you make through our Services. We only collect customer data from customers and visitors if they voluntarily submit this information to us or carry out transactions or payments via our services. We may also update and supplement personal information with information provided by third parties in accordance with applicable data protection laws.

We and/or our authorised third party service providers may automatically collect Technical Data when you visit or interact with our Services. Technical Data may include browser name, computer or device type, time spent on the website, interaction with the Services, the URL of the website you visited before and after visiting the Services, the time and date of user visits, browsing habits, IP address, operating system and internet service providers used and similar technical information.

Cookies: We use various technologies to collect and store information when you visit a Custobar website, including cookies. Cookies allow us to calculate the total number of visitors to our websites and to monitor website usage. This helps us to improve our websites and provide a better service to our users. We also use cookies to make it easier for you to use the website, for example by remembering usernames, passwords and (language) settings. We also use tracking and analytics cookies to see how well our services are received by our users. You can configure your web browser to refuse cookies or to notify you when cookies are sent. In this case, please note that some areas of our services may not function properly. Further information on cookies and how to delete them can be found at http://www.allaboutcookies.org

When you visit our website, we inform you about the different types of cookies we use and give you the option of agreeing to or rejecting individual types of cookies. Non-essential cookies are only activated once you have consented to their use.

Our website uses Cookiebot's cookie consent technology to obtain your consent to the storage of certain cookies in your browser in accordance with Article 6 paragraph 1 sentence 1 lit. a GDPR and to document this in a data protection-compliant manner. The provider of this technology is Cookiebot - Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter ‘Cookiebot’). When you enter our website, a Cookiebot cookie is stored in your browser, in which the consent you have given or the revocation of this consent is stored. This data is not passed on to the provider of Cookiebot.

The data collected will be stored until you ask us to delete it, delete the Cookiebot cookie yourself or the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Further details on data processing by Cookiebot can be found at https://www.cookiebot.com/de/privacy-policy/

Cookiebot cookie consent technology is used to obtain the legally required consent for the use of cookies.

All cookies used on the Custobar website: Cookiebot

Transmission to countries outside Europe

The Services may also include advertising provided by third parties that deliver cookies or other tracking technologies to your device so that your online activities on third-party websites or online services can be tracked for advertising purposes. These third-party services are subject to separate privacy policies. The Network Advertising Initiative provides opt-out mechanisms for some online behavioural advertising: www.networkadvertising.org/choices/. Users based in the European Union can find out about their rights in relation to online advertising at www.youronlinechoices.eu

Recipients

We do not share your personal data with third parties outside the European Union unless one of the following circumstances applies:

For legal reasons

We may disclose your Personal Data to third parties if we have a good faith belief that access to and use of the Personal Data is reasonably necessary to: (i) comply with applicable laws, regulations and/or court orders; (ii) detect, prevent or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, property or safety of Custobar, our users or the public as required by law. Where possible, we will inform you of such processing.

To authorised service providers

We may share personal data with authorised service providers who provide services to us (including data storage, sales, marketing and support services) or cooperation partners with whom we jointly organise events. Where data is processed by third parties on behalf of Custobar, we have put in place the appropriate contractual and organisational measures to ensure that your data is processed solely for the purposes set out in this Privacy Policy and in accordance with all applicable laws and regulations and subject to our instructions and appropriate confidentiality obligations and security measures.

For other legitimate reasons

If Custobar is involved in a merger, acquisition or sale of assets, we may disclose your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will notify all affected customers before the personal data is transferred or becomes subject to a different privacy policy.

With your explicit consent

We may share your personal data with third parties outside of Custobar for reasons other than those mentioned above if we have your explicit consent to do so. You have the right to withdraw this consent at any time.

Contact form and appointment booking

You can send us an enquiry or book a demo appointment at any time using the contact forms on our website. The following information is requested: first name, surname, email address, telephone number, company, field of activity. The details are marked as mandatory fields. All other data that you send us as part of the enquiry, including via the free text field, is voluntary.

We use this data exclusively for answering your enquiry or booking demo appointments and the associated communication. The legal basis for this processing of your data depends on the content of your enquiry. In principle, our legitimate interest in providing the contact functionalities and responding to your enquiry applies here. If your enquiry is aimed at concluding a contract with us, the processing takes place within the framework of this pre-contractual obligation.

Your data will be deleted as soon as your enquiry has been finally processed. If a contract is concluded, we may process the data further to fulfil the contract.

Online application

You can apply to us at any time via the online application form at The Hub. As part of the application process via our website, personal data is transmitted to us. This can be done directly via the input fields or indirectly via documents to be uploaded, such as your CV. We require the following information from you as part of a regular application: Surname, first name, email address, telephone number and professional experience. We only process your data to the extent necessary to carry out the application process. Your data will only be stored permanently for subsequent recruitment if you give us your express consent to do so.

The legal basis for the processing is the necessity for the initiation of an employment relationship. Your application data will be deleted no later than 12 months after unsuccessful completion of the application process, unless you have given us your consent to further storage.

Right of objection and cancellation

If the data processing is based on your consent or our legitimate interest, you have the right to object to the processing or revoke your consent at any time. Your objection or revocation only has effect for the future. You can contact privacy@custobar.com at any time to exercise your right of objection or revocation. If you object to processing based on our legitimate interest, we may nevertheless continue the processing if we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.

You have the right to opt out of receiving electronic direct marketing communications from us by clicking on the opt-out link included in any marketing communications we send you and choosing not to receive marketing communications from us in the future. You also have the right to stop us from using your personal data for direct marketing, market research and profiling purposes by contacting us at the addresses provided above.

Your rights

Right of access

Custobar provides you with information about the personal data we process. This means that you can contact us to ask us to inform you about your personal data that we have collected and processed and the purposes for which this data is used.

Right to rectification

You have the right to have incorrect/inaccurate, incomplete, outdated or unnecessary personal data that we hold about you corrected or completed by contacting us.

Right to erasure

You can also ask us to delete your personal data from our systems. We will comply with such a request unless we have a legitimate reason for not deleting the data. After the data has been deleted, we may not be able to immediately delete all remaining copies from our active servers and backup systems.

Right to restriction of processing

You can ask us to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may result in fewer opportunities to use our 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 exercise your rights

You can exercise these rights by sending a letter or email with your name, address, telephone number or email address to the above addresses. If your request concerns personal data in a cookie, you must include a copy of that cookie. We may request the provision of additional information necessary to confirm your identity. We may refuse requests that are unreasonably repetitive, excessive or manifestly unfounded. If you believe that our processing of your personal data does not comply with applicable data protection laws, you may lodge a complaint with your local data protection supervisory authority.

Information Security

We will take all reasonable and appropriate security measures to protect Custobar and our customers from unauthorised access to or unauthorised alteration, disclosure or destruction of personal data we hold. Measures may include encryption, firewalls, secure facilities and access rights systems. If, despite the security measures, a security breach occurs that may have a negative impact on your privacy, we will inform you as soon as possible.

Submit a complaint

If you believe that our processing of personal data does not comply with applicable data protection laws, you may lodge a complaint with the local supervisory authority for data protection. In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).

Custobar may transfer your personal data to countries outside the European Union and the European Economic Area. If we transfer data to a country that does not have an adequacy decision from the European Commission, such transfer will be subject to the provisions of the Standard Contractual Clauses adopted by the European Commission. If you would like to know more about the international transfer of your personal data, you can contact us using the contact details above.

Last update: 12 June 2024