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Privacy Policy for ReimaGO® service

Reima Oy, including its group companies (“Reima” or “we”, “us”, “our”), is committed to protecting your and your children’s privacy and complying with applicable data protection and privacy laws. Together with the Terms, the purpose of this Privacy Policy (“Policy”) is to help you understand what kind of personal data we collect in connection with our the ReimaGO® service (“Service”) and how we process such data. In this Policy the term “personal data” refers to information relating to an identified or identifiable individual (i.e. a natural person). The term “child and/or children” refers to persons under the legal age of majority in the respective country of residence or who are not of legal age to consent to the collection and processing of personal data under applicable law.

This Policy applies to personal data collected in connection with the Service. The categories of data subjects this Policy applies to are the users of the Service.

The Service may contain links to other companies’ websites and other third party services that have privacy policies of their own. We recommend that you read the privacy policies of such services. Reima is not responsible for the privacy practices or contents of any such services.

By using the Service or by submitting personal data to Reima, or by clicking “I Agree”, depending on the case, you express your consent and agreement to the processing of your personal data in the manner provided in this Policy. If you do not agree with this Policy, please do not use the Service, or provide Reima with your personal data, or grant your consent otherwise.

Reima may change this Policy from time to time or change, modify or withdraw access to the Service at any time with or without notice. The most current version of the Policy is found here.

  1. Controller
  2. Contact person for register matters
  3. Name of register
  4. What is the legal basis for and purpose of the processing of personal data?
  5. What data do we process?
  6. From where do we receive information?
  7. Collecting data of minors
  8. To whom do we disclose data and do we transfer data outside of EU or EEA?
  9. How do we protect the data and how long do we store them?
  10. Use of tracking technologies and cookies
  11. What are your rights as a data subject?
  12. Who can you be in contact with?
  13. Changes in the Policy

1 Controller

REIMA OY
KARHUMÄENTIE 3
FI-01530 VANTAA
FINLAND
+358) 9 427 20 275
(hereafter ”we” or ”Reima”)

2 Contact person for register matters

HELI VILJANEN
C/O REIMA OY
KARHUMÄENTIE 3
01530 VANTAA
PHONE: +358 20 759 5800
EMAIL: heli.viljanen@reima.com

3 Name of register

ReimaGO® customer and marketing register

4 What is the legal basis for and purpose of the processing of personal data?

The basis of processing personal data is the performance of a contract and Reima’s legitimate interest (e.g. customer relationship management, direct marketing) and/or consent of the user.

The purpose of the processing of personal data are:

  • Provision of Service. We may use your personal data to fulfil your requests, process your order or as otherwise may be necessary to perform or enforce the Service agreement between you and Reima, to ensure the functionality and security of the Service, to identify you and to prevent and investigate fraud and other misuses.
  • Development of Services. We may use your personal data to develop the Service. We may also use your personal data to personalize the Service and to provide you with information on products and services relevant to you, for example, by making recommendations and displaying customized content (with respect to personal data of children, please see section “collecting data of minors”). We may combine personal data collected in connection with the Service with other personal data we may hold about you, except where such personal data was collected for a different purpose. We may also create aggregate and statistical information based on your personal data.
  • Communicating and Marketing. We may use your personal data to communicate with you, for example, to provide information relating to the Service or to contact you for customer satisfaction queries. We may use your personal data for marketing or research purposes, for example, to conduct market research and we may, in accordance with applicable law, contact you to inform you of new products, services or promotions we or third parties may offer. Reima does not disclose your personal data to third parties for marketing purposes without your prior consent. However, you acknowledge and agree that any statistical and aggregated data, such as movement data, we collect from the Service can be analyzed and used for research and marketing purposes if done anonymously. Please see the ReimaGO® Terms of Use and section “What are your rights as a data subject” below for further information regarding direct marketing.

We use automated decision-making (inc. profiling) to identify the data subjects’ online behavior and purchase habits and create profiles based on the information. We use this information to target marketing and develop our services.

5 What data do we process?

We process the following personal data of the customer or other data subject in connection with the customer and marketing register:

  • Basic information of the data subject regarding the registration. We may collect or ask you to provide us with information such as your name, e-mail address, country of residence, postcode, as well as your user names, passwords and other such credentials that are used to authenticate users and to validate their actions, or that may be needed to provide you with the Service or to communicate with you, as well as information uploaded by you, such as location and pictures etc. We may also collect demographic information, such as language preferences and information you provide, such as your consents, preferences and feedback, information relating to your Reima products linked to the Service, your child’s information (such as his/her nickname, age and birthday) you choose to provide us with and other such information you provide us with. Please note that we do not require you to provide us with any personal data of your child to use the Service but if you do, such information will be treated as your personal data hereunder (Please see section “Collecting data of minors” below for additional information), and that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data;
  • Exercise/activity data of a child gathered via a detachable movement sensor. Such exercise/activity data can be duration and/or intensity of the exercise level and/or number of steps taken;
  • Possible direct marketing prohibitions and consents;
  • Information related to the behavior of the data subject in the services, which is used for profiling purposes such us the sites and services visited, the duration of visits/use, actions taken on the sites and in services;
  • Technical Information. Certain technical information is normally collected as a standard part of your use of the Service. Such information includes, for example, your IP-address, access times, information about your devices used and other such technical information your browser provides us with or as may otherwise be collected in connection with the Service. When you use the Service or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by the telecommunications operator as a standard part of that communication. Please also see section “Use of cookies” below;
  • Transactions. We collect or ask for information relating to your use of the Service and your other interactions with us. Such information may include, for example, details of the queries or requests you have made, details of agreements between you and Reima, records of contacts and communications, information and details relating to the material and content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points. Please note that the privacy policy of Reima available at https://www.reima.com/int/privacy-policy may further apply;
  • Information regarding the customership and contract, such as information of past and excisting contracts and orders, other transaction information;
  • Other possible information collected based on the consent of the data subject.

6 From where do we receive information?

We receive personal data concerning customers primarily from the following sources: from the data subject him-/herself, our group companies and from day care service providers.

For the purposes described in this privacy policy, personal data may also be collected and updated from publicly available sources and based on information received from authorities or other third parties within the limits of the applicable laws and regulations. Data updating of this kind is performed manually or by automated means.

7 Collecting data of minors

Our Services and Applications are not directed to individuals under the age of 13, and we request that individuals under 13 not provide personal information to us through our Services and Applications. If we learn that we have collected the personal information from a child under 13 without a consent from a parent or legal guardian or otherwise as permitted under applicable law, we will take steps to delete the information as soon as possible. If you are aware of a user under the age of 13 using a Services and Applications, please contact us at reimagosupport@reima.com.

8 To whom do we disclose data and do we transfer data outside of EU or EEA?

We may share your personal data within the Reima group of companies, including but not limited to the sales entities of Reima, or authorized third parties who process personal data on behalf of Reima for the purposes described in this Policy, such as technical service providers or marketing service partners. Such parties are not permitted to use your personal data for any other purposes.

Data may be disclosed to authorities under compelling provisions. If we decide to sell, buy, merge or otherwise reorganize our business operations in any way, this may involve us disclosing your personal data to e.g. prospective or actual purchasers of our business and their advisers.

We do not disclose or transfer personal data outside of EU/EEA.

9 How do we protect the data and how long do we store them?

Reima takes reasonable technical and organizational information security measures, such as use of firewalls, secure server facilities, encryption, access right management, and other similar measures to prevent and minimize risks associated with processing personal data and its disclosure to and use by unauthorized third parties.

Where appropriate, we may take back-up copies and use other such means to prevent accidental damage to or destruction of your personal data.

However, please note that despite our reasonable steps to protect your personal data, no website, Internet transmission, computer system or wireless connection is completely secure, which we advise you to consider e.g. when choosing, which personal data you provide us with.

We store the personal data for as long as is necessary considering the purpose of the processing. Personal data about customers is processed and retained during the customer relationship and as long as we deliver services, and after the relationship or service provision has ended for three (3) years. Personal data about potential customers is deleted or updated when it is discovered to be outdated or the data subject is deemed unresponsive to the marketing.

We regularly assess the need for data retention in light of the applicable legislation. In addition, we take reasonable measures to ensure that the personal data in the register is not incompatible, obsolete or inaccurate considering the purpose of the processing. We rectify or delete such information without delay.

10 Use of tracking technologies and cookies

When you visit the Service, information may be placed on your device to allow us to recognize your device in the form of a text file known as a “cookie”, we may also use other similar tracking technologies. Our use of cookies and other tracking technologies are intended to provide benefits to you, such as eliminating the need for you to enter your password frequently during a session. Tracking is also used for traffic analysis and anonymous demographic profiling so that we may improve our Service.

If you do not wish to receive cookies or to be subject to other tracking technologies, or want to be notified before they are placed, you may set your device to do so, if your device so permits.

Read more about our use of cookies regarding Reima.com web pages and social media from our Cookie Policy.

11 What are your rights as a data subject?

As a data subject you have a right to inspect the personal data concerning yourself, which is stored in the register, and a right to require rectification or erasure of the data. You also have a right to withdraw or change your consent, in cases where the processing of the data is based on your consent.

As a data subject, you have a right, according to EU’s General Data Protection Regulation (applied from 25.5.2018) to object to the processing or request restricting the processing of your personal data. Additionally, you have a right to request your data to be delivered to you in a standard format, in case where the processing of data is based on your consent or a contract between us.

You also have a right to lodge a complaint with a data protection authority in your jurisdiction or with the power to investigate processing concerning your personal data.

For specific personal reasons, you also have a right to object to profiling and other processing concerning you, when processing of the personal data is based on our legitimate interest. In connection to your claim, you should identify the specific grounds on which you object to the processing. We can refuse to act on such a request on the basis of the privacy legislation.

As a data subject you have the right to object to profiling in so far as it relates to direct marketing.

12 Who can you be in contact with?

All contacts and requests concerning this privacy notice must be submitted in writing or in person to the person mentioned in section two (2).

13 Changes in the Policy

Should we make amendments to this Policy we will place the amended statement on our website, with an indication of the amendment date. If the amendments are significant, we may also inform you about this by other means, for example by sending an email or placing a bulletin on our homepage. We recommend that you review this Policy from time to time to ensure you are aware of any amendments made.