Privacy policy for commercial activities

This privacy policy applies to all external commercial activities by Limber Way Oy and its other entities, like Hotelway, and all of the websites operated by them: www.limber-way.com and www.hotelway.me.

We pledge to honor the following privacy protection policy, designed with our customers in mind. We collect information responsibly, in accordance with the applicable data protection legislation. We ask for personal information only for our own customer service as well as marketing activities, and to give you access to information such as newsletters. We will NOT distribute any additional information to third parties without your specific permission.

If you are using our Hotelway app, it has another Privacy Policy, which can be accessed directly through the Hotelway application.

1. Controller & Contact information

Limber Way Oy

Artturinkatu 2 C, 20200 Turku, Finland

+358 20 730 3888

Email: hq@limber-way.com

2. Filing systems

This privacy policy describes how we process the personal data of our customers, potential customers, and interest groups.

3. For what purposes we use your personal data?

Personal data is collected and used within the limits defined by the applicable data protection legislation to take care of and develop customer relationships and to offer, sell, market, deliver orders, and develop the services and products of Limber Way Oy and its main partners.

Personal data is used to help us better understand our customers and to help us conduct regular research into the trends and preferences of our customers. This market research and its raw data will be held within Limber Way Oy and will never be sold, distributed, or forwarded to third parties without our customers' explicit consent.

Information collected from the data subjects will be used for direct marketing purposes only, unless the data subject prohibits such use.

4. What is our data processing based on?

Processing of your personal data is based on the following grounds of the EU's General Data Protection Regulation (one or more purposes may apply simultaneously):

a) Processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract.

b) Processing is necessary for compliance with a legal obligation to which the controller is subject (for example the duty to keep the records based on the Accounting Act).

c) Processing is necessary for the purposes of the legitimate interests pursued by Limber Way Oy.

d) You have given consent to the processing of your personal data.

The legitimate interests of Limber Way Oy or a third party referred to in point c) above may include, amongst others, the following matters:

• the right to promote the sales of Limber Way Oy's products and services by way of direct marketing, including profiling for the purposes of marketing and sales;
• business development;
• investigation of possible malpractice.

5. Information content

The filing systems include the following information, either in part or in full:

• Customer first and last name
• Company information and industrial classification
• Professional title
• Email address
• Postal address
• Phone number
• Nationality
• Information pertaining to all purchases and orders, such as invoicing address and payment details
• Any follow-up information pertaining to the customer's purchases
• Feedback given by the customer
• Notes of discussions with customers

o when the customer's data was put in to the filing system

o campaigns, promotions, and other communication directed to the customer, as well as their use, including participation in events

o interests and other information or survey data provided by the customer

o direct marketing choices

o use of the customer's rights related to the customer's personal data (such as right to rectification and right to data portability)

o information of the use of our digital services as well as digital content created by the customer

o automatically collected data (such as IP Address, the customer's device's operating system, browser type and language)

o mobile device identifiers (such as the customer's unique device ID and device name)

o recordings of customer service telephone conversations, as well as e-mail and chat correspondence

We do not collect credit card information from our customers.

HOWEVER,if you are a newsletter subscriber, the only information we have about you, is your email-address.

6. Where do we collect the personal data from?

Our filing system is derived from information given by our customers when registering for our newsletters or other business. This information is collected using an online form, as well as on paper, by phone, by email, by business cards or during the purchasing process of a service and/or product.

We may gather personal data from business-to-business customers when the representative of the company gives personal data of other employees to us. We may also obtain and update the personal data in our filing systems from officials and companies offering personal data services.

7. With whom might we share your personal data

Limber Way Oy does not sell, lease, or otherwise disclose your personal data to third parties outside of the Limber Way Oy and its distribution partners unless otherwise stated below.

The name of the organization of our customer can be publicly distributed if we use you as a reference. There is a specific paragraph in our business contracts stating it.

Limber Way Oy may share your personal data based on a valid order from a court or other official body with sufficient authority.

Limber Way Oy may share your personal data as part of any merger, acquisition, sale of company assets, or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy, or receivership in which your personal data would be transferred to another entity as a result of such a proceeding.

8. How long do we process your personal data?

The controller will process the personal data of its customers until the end of the business relationship plus 6 years. Potential customers' data is processed in our marketing database until a customer relationship has started or until the data subjects asks his/her data to be deleted.

9. Reviewing, updating, and correcting of personal data

The data subject has the right to check, review, and update or correct his/her information maintained in the filing system at any time. Customers must inform us if any personal data changes in order to keep their record in the filing system up-to-date. For additional questions, or to review, update, correct or remove personal data, please email o hq@limber-way.com.

10. The right of erasure ("right to be forgotten")

If a customer misuses our service, conducts illegal activity via the service, or if the information entered is out of date, Limber Way Oy reserves the right to delete the personal data associated with this individual.

You have the right to obtain the erasure of personal data that concerns you from Limber Way Oy without undue delay on any of the following grounds:

(a) your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; e.g. you do not wish to receive our newsletters

(b) you withdraw consent on which the processing is based and where there is no other legal ground for the processing;

(c) you object to the processing and there are no overriding legitimate grounds for the processing;

(d) your personal data have been unlawfully processed;

(e) your personal data have to be erased for compliance with a legal obligation in Union or member state law to which Limber Way Oy is subject;

(f) the personal data have been collected in relation to the offer of information society services.

However, you do not have the right of erasure if the processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation which requires processing by Union or member state law to which Limber Way is subject; or

(c) for the establishment, exercise, or defence of legal claims.

11. Right to data portability

You have the right to receive the personal data concerning you, which you have provided us in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller where the processing is based on consent or on a contract and the processing is carried out by automated means.

12. Do we make decisions affecting you based on automated means?

Limber Way does not make decisions based solely on automated processing, which produces legal effects concerning you or similarly significantly affect you.

13. Principles of protection

Access to any personal information by Limber Way will be restricted to designated individuals with a username and password. Access to this database will be given only to specifically appointed people.
The individuals managing the filing system are bound to professional secrecy.

Limber Way's services may be provided using resources and servers located in various countries around the world (e.g. providing newsletters). Therefore, Limber Way Oy may transfer your personal data outside the country where you use our services, including to countries outside the EU and EEA that do not have laws providing specific protection for personal data or that have different legal rules on data protection.

In such cases, Limber Way will ensure that a legal basis for such a transfer exists and that adequate protection for your personal data is provided, as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

We at Limber Way Oy are concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to Limber Way or guarantee that your information stored by the Limber Way may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. When you enter information (such as email-address) on our order forms, we encrypt all transmitted data using HTTPS with TLS (Transport Layer Security). However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

We do not collect credit card information from our customers.

We may modify this privacy policy, and if we make material changes to it, we will provide notice on our website or by other means to provide you with the opportunity to review the changes before they become effective. Your continued use of our products and services after we publish or send a notice about our changes to this privacy policy means that you have become bound by the updated privacy policy.

Do you have any additional questions about our privacy protection?

We are happy to answer any questions you may have regarding our privacy protection policy! Feel free to send us an email at hq@limber-way.com.

Our privacy policy was last updated on 25th of May 2018.