1.1 We are Exaget Oy (referred to as “we”, “us” and “Exaget”) and we are committed to protecting and respecting your privacy when you are:
(a) visiting any website maintained by us including without limitation the website at www.exaget.com, www.utuneme.com, www.utune.me and such other country-specific URL’s as we may operate from time to time and our social networking pages (together the “Website”);
(b) accessing or using any mobile or other software application operated by us, including any applications operated by us on behalf of our partners (together the “App”); and/or
(c) communicating electronically with us.
1.3 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By disclosing your personal information to us by using the Website or speaking to us over the telephone you consent to the collection, storage and processing of your personal information as stated in this policy.
1.4 Exaget uses the personal information we collect from you to provide our service to you. We will not rent, sell or share your personal information with any other company for its own marketing purposes without your consent except where mentioned in this policy.
1.5 This policy constitutes a register description of Exaget’s customer register as provided in Section 10 of the Finnish Personal Data Act (523/1999, as amended). Exaget is also registered with the Information Comissioner’s Office, United Kingdom, with register number Z3423111.
1.6 The data controller for any personal data processed as described in this policy document is
Energiakuja 3, 00180 Helsinki
CONTACT IN MATTERS REGARDING THE REGISTER:
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
2.1 We may collect, store and use the following kinds of personal information:
(a) when you register to access our service through the Website or App, you may be asked to complete a form which will require you to provide information including your name, email address, age, gender, language preferences and location;
(b) from time to time, you may be able to provide additional optional information such as your listening preferences and topics or areas of interest;
(c) in order to provide our services to you, we may collect your geo-location and update this from time to time whilst you are using our services through a mobile device or an application for any other device platform, or via the Website;
(d) when you contact us by email or telephone or through the Website or App, we may ask you to provide some or all of the information set out in paragraph (a) above;
(e) we may collect, store and use information about your computer, mobile device or other item of hardware through which you access the Website or App and your visits to and use of the Website and/or App (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, mobile network operator, operating system, memory card data, sound card data, installed media players, referral source/exit pages, length of visit, page/screen views, clicks inside any user interface, website navigation and search terms that you use, internet radio stations and/or programs listened to, length of listening, advertisements listened to, and user actions taken when listening ); and
(f) if you access the Website or App through a social networking profile, we may collect, store and use the details of that social networking profile and any information contained therein in order to populate any forms you might wish to complete.
2.3 We will not disclose your personal information without your consent except as set out in paragraph 4 below.
2.4 We may also ask you to complete surveys and give feedback that we use for research purposes, although you do not have to respond to them.
3. HOW DO WE USE PERSONAL INFORMATION?
3.1 We may use your personal information for the following purposes:
(a) to manage and administer the Website and App;
(b) to improve your browsing and user experience by personalising the Website and App;
(c) to enable you to use the Website and/or App;
(d) to send you newsletters and other relevant and targeted promotional communications;
(e) to deal with enquiries, complaints and feedback from you and our other users;
(f) to resolve disputes between users arising from your use of the Website and/or the App;
(g) to provide third parties with statistical anonymised information about our users;
(h) to send you emails offering you to take part in a survey and/or give feedback;
(i) to analyse and improve the services offered on the Website and App; and
(j) to customise and personalise any content, including without limitation any advertisements, heard or seen by you when using or accessing the Website and App.
4. WHEN MIGHT WE DISCLOSE PERSONAL INFORMATION?
4.1 Save as detailed below, except to the extent required by any applicable law or governmental or judicial body, or where we consider in our sole and absolute discretion that it is required to be disclosed to resolve a dispute, or with your express consent we will not disclose your personal information to any third party.
4.2 Where you have completed a survey or given feedback on any other user, we may publish some or all of the information you have provided to us in the survey and/or feedback on the Website and/or on our social networking profiles. Without your prior written consent, we will not publish your name or company name in connection with any comments or feedback.
4.3 We may sell or buy businesses or assets. In the event of a sale, merger, reorganisation, dissolution or similar event, we may transfer your Personal Data as part of the assets transferred.
4.4 We may share information between other members of our corporate group and/or any agents, consultants and third parties performing services for us or in conjunction or ancillary to the services we provide to you through the Website and/or App.
5. NEWSLETTERS AND OTHER PROMOTIONAL COMMUNICATIONS
5.1 If you wish to subscribe to our newsletter or wish to receive other targeted and relevant promotional communications from us or other carefully chosen affiliates, we offer you the option to “opt-in” to this service. If you change your mind and wish to stop receiving any such communications, please either email us at firstname.lastname@example.org or click the “unsubscribe” link in any email from us.
6.1 Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Website and App (including user site preferences or the contents of electronic shopping carts).
6.2 The data collected by cookies is anonymous. You can delete all cookies that are already on your computer’s hard drive by searching for files with “cookie” in it and deleting them. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Website and/or the App. For more information about cookies, please visit: www.allaboutcookies.org
6.3 Web beacons consist of a small string of software code that represents a graphic image request on a web page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a web page or email. Web beacons can be used for many purposes – including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization. Web beacons used by www.exaget.com collect only anonymous data.
6.4 In order to improve the Website and the App and the services we offer you, we may use (temporary and persistent) cookies, authorized third parties cookies, web beacons and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behavior, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Website and the App.
6.5 In order to understand how people use our website and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use on an anonymous basis certain information (including the total number of transactions, viewed web pages, referring/exit pages, platform type, date/time stamp information and details like the number and location of mouse clicks on a given page, mouse movements, scrolling activity and the search words you use while being on and using the Website and the App.
7. WHERE WE STORE YOUR PERSONAL DATA
7.2 All information you provide to us is stored on our secure servers.
7.3 We take the security of your personal data very seriously. In particular we use all reasonably endeavours to ensure that appropriate security measures are in place to protect your personal data. Unfortunately, the transmission of information via the internet is not completely secure and so we cannot guarantee the security of your data transmitted through the Website or the App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 We transmit personal information using Secure Sockets Layer (SSL) software which encrypts information you input. Further, to the extent that we collect any credit card or bank account information from you, we will only reveal the last four digits of your credit card number when confirming an order. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
8. LINKS TO THIRD PARTY WEBSITES
9. YOUR RIGHTS
The Act gives you the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us email@example.com.
10. ACCESS TO INFORMATION
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.