Welcome to FABBLO - powered by Sirea and our website at fabblo.com. At Sirea, we take the protection of your data very seriously. In the following, we explain what information we collect when you use our website and services, and how it is used.
The Basics
What law applies?
Our use of your Personal Data is subject to the Data Protection Act (DPA - Tietosuojalaki) and the EU General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.
What is Personal Data?
Personal Data is any information about personal or factual circumstances that relate to a person. This may include name, date of birth, email address, postal address or telephone number, but also online identifiers such as IP addresses or device IDs.
What is processing?
"Processing" is any operation or set of operations that is performed on Personal Data, whether or not it is done automatically. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party within the meaning of the Data Protection Act (DPA) and the GDPR is Sirea which powers FABBLO app, Hermanninsaarentie, 06400 Porvoo, Finland (“Sirea”, “we”, “us”, or “our”).
If you have any questions about this policy or our data protection practices, please contact us using email AT fabblo.com or write to us at the above address.
What are the legal bases for processing?
According to the DPA and the GDPR, we should have at least one of the following legal bases to process your Personal Data:
(Where necessary, we process your data beyond the actual performance of the contract to protect legitimate interests of us or third parties. Examples include:
(If you have given us your consent to process Personal Data for specific purposes).
(Processing to comply with our legal obligations.)
Am I obliged to provide data?
In the context of our business relationship, you are only obliged to provide Personal Data that is required for the establishment, implementation and termination of a business relationship or that we are legally obliged to collect. Without this data, we usually have to refuse to conclude a contract or can no longer fulfil an existing contract and may have to terminate it.
Data that we collect automatically
Log data
Each time you visit our website, our system automatically collects the following data from the visiting device and stores it in a so-called log file: (i) name of the file accessed, (ii) date and time of the visit, (iii) amount of data transferred, (iv) notification of successful retrieval, type of browser and version used, (v) IP address (identification of the user's device), (vi) operating system of the visiting device, (vii) Internet service provider of the visiting device, (viii) website from which you access our website, and (ix) which pages of our website you access. The legal basis for this processing is our legitimate interest.
Hosting
The hosting services used by us for the purpose of operating our website is Hetzner of Industriestr. 25 91710 Gunzenhausen, Deutschland. In doing so Hetzner, processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of contractual services and the conclusion of the contract for our services).
Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyse your behaviour on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
As set out in the Finnish Act on Electronic Communications Services (“ECS”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
Cookie consent
Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.
Links to other websites
Please note that if you use a link from our website to a third-party website, that third-party may also set new cookies that are not covered by this policy. In such cases, we recommend that you read the cookie policy on the third-party website itself.
Third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("services").
This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.
The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,
Data we collect directly
Contact
The processing of Personal Data depends on the nature of your contact. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also contain certain Personal Data. The Personal Data collected when you contact us is used to process your request, and the legal basis is your consent.
Registration
As part of the registration process, users provide their a) Full Name; b) User Name; c) Email address; d) Password. The data provided will be used for the purposes of creating and using the account and providing and/or using our services. In the context of the use of our registration and the use of your account, the legal basis for the data processing is the fulfilment of our contractual obligations and, in individual cases, the fulfilment of our legal obligations as well as consent.
When you use our services
We process the Personal Data that arises when you use our services in order to provide our contractual services. In particular, this includes our support, correspondence with you, invoicing, fulfilment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of the fulfilment of our contractual obligations and our legal obligations.
Also please note that when using our services, you become the data controller and we become the data processor in accordance with Chapter 4 of the GDPR. Where we process your Personal Data as data processor or in other words on behalf of you, we will process the Personal Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us.
We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.
Further, please be advised that:
Administration, financial accounting, office organisation, contact management.
We process data in the context of administrative tasks and the organisation of our business and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the provision of our contractual services. The processing bases are our legal obligations and our legitimate interest.
Payment Data
If you make a purchase your payment will be processed via our payment service provider Stripe of 510 Townsend Street San Francisco California 94103. Payment data will solely be processed through Stripe/ PayPal and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.
Marketing
If you have given us your separate consent to process your data for marketing and promotional purposes, we are entitled to contact you for these purposes through the communication channels for which you have given your consent.
You may give us your consent in a variety of ways, such as by checking a box on a form asking for permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. In cases where your consent is implied, it is based on the assumption that you could reasonably expect to receive a marketing communication based on your interactions or contractual relationship with us.
Direct marketing is typically by email, but may include other less traditional or new channels. These forms of contact are managed by us or by our contracted service providers. Any direct addressed marketing sent or conducted by us or on our behalf will provide you with the opportunity to opt out or exclude yourself.
Economic analyses and market research
For business reasons, we analyse the data we have on business transactions, contracts, enquiries, browsing behaviour etc., whereby the group of persons concerned may include contractual partners, interested parties, and users of our services.
The analyses are carried out for the purpose of business evaluations and market research. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as summarised data).
General Principles
Who receives my information?
Within Sirea, those who have access to your information are those who need it to fulfil our contractual and legal obligations.
Processors used by us may also receive data for these purposes. These are companies in the areas of IT services, telecommunications, and sales and marketing. If we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of Personal Data in accordance with the relevant legal provisions.
Data is only passed on to third parties within the framework of the legal provisions. We only pass on user data to third parties if this is necessary, for example, for contractual purposes or due to legitimate interests in the economic and effective operation of our company, or if you have consented to the transfer of data.
How long will my data be stored?
To the extent necessary, we process and store your Personal Data for the duration of our business relationship, which includes, for example, the initiation and execution of a contract.
In addition, we are subject to various retention and documentation obligations, which result, among other things, from the statutory minimum retention periods and other retention periods prescribed in this sense, e.g. retention periods under tax or commercial law. Depending on the document and the legal regulation, the periods specified there for storage and documentation are two to six years.
How do we secure your data?
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. In addition, we have taken numerous security measures ("technical and organisational measures"), such as encryption or access only when necessary, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, Internet-based data transmissions can always have security vulnerabilities, so that absolute protection cannot be guaranteed. And databases or records containing Personal Data may be breached inadvertently or by unlawful intrusion. If we learn of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as soon as possible after the breach is discovered.
Is data transferred to a third country?
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
Special category data
We do not process special category data unless it is necessary for the use of our services and explicit consent has been given.
Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or share it with third parties.
Automated Decision Making
Automated decision making is the process of making a decision by automated means without human involvement. Automated decision making does not occur.
Do Not Sell
We do not sell your personal information.
Your rights and privileges
Rights to protect your data
Under the DPA and the GDPR, you may exercise the following rights:
If you have any questions about the type of Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your data
If you believe that the data we hold about you is inaccurate or that we are no longer entitled to use it and you wish to request that it be rectified or erased, or object to its processing, please contact us.
Withdrawal of your consent
You may withdraw any consent you have given at any time by contacting us. The legality of the data processing carried out until the withdrawal remains unaffected by the withdrawal.
Request for information
If you would like to make a request for information about your data, you can inform us in writing. We will respond to requests for information and correction as quickly as possible. If we are unable to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with the personal information you have requested or to make a correction, we will tell you why.
Complaint to a supervisory authority
You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.
The national supervisory authority in Finland is Data Protection Ombudsman (tietosuoja@om.fi).
Changes
This Privacy Policy was last updated on 27.09.2024 and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary.