Last updated 9 June 2020

This Privacy Policy applies to processing of personal data of the users ("Users") of the services ("Services") provided by Seaber Oy ("Seaber")  including the personal data we collect from you when you use our website. This Privacy Policy informs why and how Seaber collects, uses or shares personal data and what rights the Users have.

1. Data controller

The data controller in accordance with the applicable data protection law is Seaber Oy (hereinafter together "Seaber", "we", "us" or "our"). Seaber is responsible for ensuring that personal data is processed in compliance with this Privacy Policy and applicable data protection laws, such as GDPR.

Contact details of the controller:

Seaber Oy

Business ID 2855258-7

Keilaranta 1

02150 Espoo, Finland 

The Primary contact person is Sebastian Sjöberg, email info@seaber.io

2. Collection of personal data

Seaber may process the following categories of personal data:

• Basic information about the User, e.g. name and email address;
• Basic work-related contact information about the User, e.g. job title, company name, email address and phone number; and
• Basic customer relationship details, e.g. contract and payments and billing information; and 
• Data collected of the use of Services, e.g. timestamps and log data, IP address and other technical data.

The primary source of the personal data is the data provided by the User itself when using the Services. Seaber may also collect information from publicly available sources, such as address directories. 

3. Purposes and legal basis for processing personal data

Seaber processes personal data for the following purposes:

(1) Services

The primary purpose of collecting personal data is to provide the Services, manage customer relationship and to issue accurate charges for the use of Service. The processing of personal data in this case is based on the contract between the User and Seaber. This concern for example the data collected during signing up for the Service, by using the Service and the technical data needed to run the Service in a secure manner. 

(2) Marketing

Users' personal data will be used to manage communication with the Users, inform about new features, solicit feedback and for other marketing purposes. From data protection perspective, this processing is primarily based on Seaber's legitimate interest to provide Users with relevant and up-to-date information as part of the Services and customer relationship as well as to promote our Services. 

Electronic marketing may also be based on User's consent when required by applicable data protection law.

(3) Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website
• Enabling you to view our videos

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – Our Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Our Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

(4) Service development

Seaber's goal is to provide high quality Services and give the Users relevant information about those Services. Therefore, we may use personal data to analyze the market and use of Services for the purpose of developing and improving the quality of the Services. This processing is based on our legitimate interest to develop and improve our Service.

4. Sharing of personal data

Seaber may disclose personal data to third parties in the following cases: 

• When required by law such as to comply with requests by competent authorities;
• If Seaber is involved in a merger, acquisition, or sale of all or a portion of its assets;
• When we believe in good faith that disclosure is necessary to investigate fraud, to protect Users’ safety or our rights.

Furthermore, we may use third party service providers when providing the Services. However, our trusted service providers act on our behalf and Seaber will be responsible for the use of personal data. 

5. Transfer of personal data outside of EU/EEA

Personal data is processed within EU/EEA.

OR

Personal data may be processed outside of EU/EEA by [Seaber / our subcontractors]. To the extent personal data is transferred to a country outside of the EU/EEA, Seaber will use the required established mechanisms that allow the transfer to [these service providers in those] thirds countries, such as the Standard Contractual Clauses approved by the European Commission or rely on the so-called Privacy Shield for those service providers located in the U.S that are Privacy Shield-certified.

6. Retention of personal data

The personal data will be retained only for as long as necessary to fulfill the purposes defined in this Privacy Policy. Primarily, personal data will be retained during the customer relationship or as long as the User uses the Services. After that personal data will be removed except when retention is required by local laws or contractual rights or obligations by either party, for example for billing purposes.

7. Rights of Users

Users have the following rights:

• The right to request access to personal data about himself/herself;
• The right to request rectification, restriction or erasure of personal data. However, please note that certain information is strictly necessary in order to fulfil the purposes defined in this Privacy Policy and may also be required by law. Therefore, the deletion of such data may not be allowed by the applicable law, which prescribes mandatory retention periods;
• The right to object for processing, that is based on legitimate interest of Seaber provided that the User can demonstrate compelling legitimate grounds;
• The right to object to processing for marketing purposes and prevent from receiving future direct marketing;
• If processing of personal data is based on consent, the User has the right to withdraw consent at any time. The withdrawal will not affect the lawfulness of the processing carried out before the withdrawal; and
• Users have a right to data portability, i.e. right to receive the personal data in a structured, commonly used machine-readable format and transmit the personal data to another data controller, to the extent required by applicable law. This applies for personal data processed based on the customer contract or the User's consent.

Please send above-mentioned requests to Seaber at info@seaber.io.

Users have a right to file in a complaint to the national data protection authority in the EU/EEA. In Finland the competent authority is the Data Protection Ombudsman.

8. Security

We maintain reasonable security measures (including physical, electronic, and administrative) to protect personal data from loss, destruction, misuse, and unauthorized access or disclosure. For example, we limit access to personal data to authorized employees and contractors who need to know that information in the course of their job description and third party processors who may only process data in accordance with our instructions.

Although we endeavour to provide reasonable security measures for personal data, no security system can prevent all potential security breaches.

9. Changes to this privacy policy

Seaber reserves the right to amend this Privacy Policy from time to time. Seaber will inform Users of possible changes by using reasonable and available channels.