Organization Fly Nano Ltd (later “we”) respects your privacy and is dedicated to protecting the privacy of persons using the Services covered by this Privacy Notice (see section “Scope” below for the definition of the Services). This Privacy Notice helps you to understand what personal information/data (“Personal Information”) we collect, and how we use it. “Personal Information” refers to information, which allows a person to be directly or indirectly identified as an individual person. We also collect “non-personal information” meaning it can’t be used to specifically identify anyone. Non-personal information may also result from removing the personally identifiable parts from Personal Information. We collect and use both types of information and combinations of both types. This Privacy Notice applies to your use of the Services and you should read this document before using the Services.
1. Controller and contact information
Data Controller: Fly Nano Oy Name: Fly Nano Oy (later “Fly Nano”) Company-ID: 2351443-4 (Company registered in Finland) Email: firstname.lastname@example.org Address: Mikonkatu 19 B, 00100 HELSINKI, FINLAND Controller representative: Joonas Rajamäki / email@example.com
This Privacy Notice covers all data collection in concerning all Services provided by Fly Nano. Services include:• Sales of FlyNanos and all other related products and service • Providing newsletters with updates and marketing messagesAll persons (data subjects) whose personal data is collected in connection to the Services (/register) described above.
3. Information Collected and Sources of Information
The information we collect may include the following categories of data:• Contact information (name, address, telephone numbers, email) • Organization name • Personal preferences relating to our Services • Website analytical data (e.g. location, device, language and behavior data) • Financial characteristics (credit/debit card details, bank account number, credit data, property/ownership, earnings, loans, transactions We collect the information from the following sources:• Mailing list participants • Physical and electronic agreements • Physical and electronic contact information forms • Received emails and calls • Website www.flynano.com • Information you give us to us when you sign up to use our Services • Automatically gathered information when you use our Services • Information from third parties in relation to our ServicesData is collected and extracted from flynano.com, mailing list, emails and physical agreements. Privacy settings are adjusted if needed and updated version is always found on flynano.com.
4. Purpose and legal basis of the processing of Personal Information
The purposes of the processing of Personal Information may include:• Service offering and maintenance • Customer relationship management • Customer support • Human Resources management • Information Security • Sales and marketing purposesBasis of the processing the Personal Information include consent, contract and legitimate interest given to Fly Nano.
Consent to collect data is required when joining our mailing list. Consent may be asked also when signing agreements or similar documents. If you believe that we might have any information from or about a child under the age that requires parental consent, without a parental consent, please contact us at firstname.lastname@example.org.
Withdrawal of consent
For the personal data processing that you have given your consent you can withdraw your consent at any time regarding further processing of your personal data. We will comply with such request unless there is another legitimate ground to process the data. If consent is used, information of how the consent can be withdrawn e.g. by adjusting the privacy settings or contacting the organization by email.
6. Processing operations
7. Retention of Personal Information
Personal Information collected is retained pursuant to this Privacy Notice for the period necessary to fulfil the purposes outlined in this Privacy Notice unless a longer retention period is required by law. Thereafter, the Personal Information will be deleted within a reasonable timeframe or rendered anonymous. Still, we will hold the information as long as we need to in order to provide our services and products to you in accordance with (i) applicable law, or (ii) as long as is set out in any relevant contract you have with us. We will not generally hold your information longer than 10 years after the last interaction between the parties. The retention periods depend on the purpose of the processing and type of the information. We review our retention periods for personal information regularly.
8. Disclosing Information
If you have received any unauthorized or inappropriate advertisement or other marketing through our Services, we request you to contact us at email@example.com We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business. In exceptional cases, Personal Information may be disclosed to third parties if required under any applicable law or regulation or order by competent authorities, or to enforce the Terms of Service and to investigate possible infringing use of the Services as well as to guarantee the safety of the Services.
9. Protection of Information
We commit to adhere to the security provisions of applicable data protection regulation(s), as well as to process Personal Information in compliance with good processing practices. Our personnel and processors that process Personal Information are obliged to keep Personal Information strictly confidential. Access to personal information is only granted to those employees that need the information to perform their work tasks. All Personal Information is protected by appropriate industry standards, technical and organizational safety measures. We inform the authorities and users of our Services of data breaches according to applicable information security and data protection regulation(s).
10. Rights of the Data Subjects and Contact Information
Right to access and correct
You have the right to obtain information from us of what personal data we hold about you. You have the right to have corrected and/or removed any incorrect, incomplete, outdated, or unnecessary personal data we hold about you.
Right to object and restriction of processing
You have the right to object to certain types of processing of your personal data, including direct marketing, if such data are processed for other purposes than purposes necessary for the performance of our Services or for compliance with a legal obligation. You may also object any further processing of personal data after prior given consent. If you object to the further processing of personal data, this may lead to fewer possibilities to use our Services. You may request us to restrict processing of certain personal data. This may however lead to limited possibilities to use our Services.
Right to erasure
You have the right to ask us to delete the personal data we hold about you. We will comply with such request unless we have a legitimate ground to not delete the data. After the data has been deleted, we may not immediately be able to delete all residual copies from our active servers and backup systems. Such copies shall be deleted as soon as reasonably possible.
Right to data portability
You have the right to receive personal data provided by you to us, in a structured, commonly used format. You have the right to transmit the data to another controller. You may also ask to have the personal data transmitted directly to another controller, if technically feasible.
Objecting direct marketing and withdrawal of consent
You can deny any direct marketing and withdraw your consent to electronic direct marketing. You can always withdraw also any other consent including parental consent. See separate chapter on Consent.
How to use the rights
These rights can be used by sending a letter or e-mail to us on the addresses set out below, including the following information: name, phone number, login information and details of the Services you have used. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.1 Letter to: Fly Nano Oy, Mikonkatu 19 B, 00100 Helsinki, Finland E-mail to: firstname.lastname@example.org
Right to lodge a complaint with the supervisory authority
In case you consider our processing activities of personal data to be inconsistent with the applicable data protection regulation, a complaint may be lodged with the data protection supervisory authorities.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time, and at our sole discretion. All changes hereto will be made available on flynano.com. We will inform of the changes in the Services by email, if available, in case of any significant changes affecting your rights.
1NOTE! The controller is also obliged to inform the processors and recipients of the data subject’s request to correct, restrict usage or erase his/her personal data. If the data has been made public, the controller is also obliged to take reasonable steps to inform the other controllers which are processing the data of the data subject’s requests. Informing other controllers in mandatory unless it proves impossible or involves disproportionate effort.
This Privacy Notice has been published on 1st of June 2018.