Last updated May 23, 2020
for choosing to be part of our community at Heimo Solutions Oy
”, “we”, “us”, or
“our”). We are committed to protecting your personal information and your right to
privacy. If you have any questions or concerns about our
, or our practices with regards to your personal information, please contact us at
mobile application, Nalli
and use our services, you trust us with your personal
information. We take your privacy very seriously. In this
, we seek to explain to you in the clearest way possible what information we
collect, how we use it and what rights you have in relation to it. We hope you take some time to
read through it carefully, as it is important. If there are any terms in this
that you do not agree with, please discontinue use of our
Apps and our
applies to all information collected through our
mobile application, Nalli
("Apps"), and/or any related services, sales, marketing or
events (we refer to them collectively in this
as the "Services").
Please read this
carefully as it will help you make informed decisions about sharing your
personal information with us.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. DATA BREACH
CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS POLICY?
HOW CAN YOU CONTACT US ABOUT THIS POLICY?
1. WHAT INFORMATION DO WE
Personal information you
disclose to us
In Short: We collect personal information that you provide to
We collect personal information that you voluntarily provide to us when
registering at the
expressing an interest in obtaining information about
us or our products and services, when participating in activities on the
or otherwise contacting us
personal information that we collect depends on the context of your interactions with us and the
Apps, the choices
you make and the products and features you use. The personal information we collect can include the
Publicly Available Personal Information. We collect
phone numbers; and other similar
Personal Information Provided by You. We collect
app usage; and other similar
personal information that you provide to us must be true, complete and accurate, and you must notify
us of any changes to such personal information.
Information automatically collected
Short: Some information — such as IP address and/or browser and
device characteristics — is collected automatically when you visit our
We automatically collect certain information when you visit, use
or navigate the
information does not reveal your specific identity (like your name or contact information) but
may include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our
Apps and other
technical information. This information is primarily needed to maintain the security and
operation of our
Apps, and for
our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies
and similar technologies.
Online Identifiers. We collect
devices; and other similar
collected through our Apps
We may collect
information regarding your
when you use our
If you use our
Apps, we may also collect the following information:
Mobile Device Access. We may request access or
permission to certain features from your mobile device, including your mobile device's
contacts, and other
features. If you wish to change our access or permissions, you may do so in your device's
Mobile Device Data. We may automatically collect
device information (such as your mobile device ID, model and manufacturer), operating
system, version information and IP address.
Push Notifications. We may request to send you push
notifications regarding your account or the mobile application. If you wish to opt-out from
receiving these types of communications, you may turn them off in your device's
2. HOW DO WE USE YOUR
Short: We process your information for purposes based on
legitimate business interests, the fulfillment of our contract with you, compliance with
our legal obligations, and/or your consent.
We use personal information collected via our
Apps for a
variety of business purposes described below. We process your personal information for these
purposes in reliance on our legitimate business interests, in order to enter into or perform
a contract with you, with your consent, and/or for compliance with our legal obligations. We
indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To enable user-to-user
communications. We may use your
information in order to enable user-to-user communications with each user's
Short: We only share information with your consent, to comply
with laws, to provide you with services, to protect your rights, or to fulfill business
process or share data based on the following legal basis:
- Consent: We may process
your data if you have given us specific consent to use your personal information in a
- Legitimate Interests: We
may process your data when it is reasonably necessary to achieve our legitimate business
- Performance of a
Contract: Where we have entered into a contract with you, we may process your
personal information to fulfill the terms of our contract.
- Legal Obligations: We may
disclose your information where we are legally required to do so in order to comply with
applicable law, governmental requests, a judicial proceeding, court order, or legal process,
such as in response to a court order or a subpoena (including in response to public
authorities to meet national security or law enforcement
- Vital Interests: We may disclose your
information where we believe it is necessary to investigate, prevent, or take action
regarding potential violations of our policies, suspected fraud, situations involving
potential threats to the safety of any person and illegal activities, or as evidence in
litigation in which we are involved.
More specifically, we may need to process your data or share
your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection
with, or during negotiations of, any merger, sale of company assets, financing, or
acquisition of all or a portion of our business to another company.
Third-Party Advertisers. We may use third-party advertising companies to serve ads
when you visit the
These companies may use information about your visits to our Website(s) and other
websites that are contained in web cookies and other tracking technologies in order to
provide advertisements about goods and services of interest to you.
collect and store your information.
beacons and pixels) to access or store information. Specific information about how we use such
5. HOW LONG DO WE KEEP YOUR
Short: We keep your information for as long as necessary to
fulfill the purposes outlined in this
unless otherwise required by law.
We will only keep your personal information for as long as it
is necessary for the purposes set out in this
, unless a longer retention period is required or permitted by law (such
as tax, accounting or other legal requirements). No purpose in this policy will require us
keeping your personal information for longer than
the period of time in which users have an account with us
When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize it, or, if this is not possible (for
example, because your personal information has been stored in backup archives), then we will
securely store your personal information and isolate it from any further processing until
deletion is possible.
6. HOW DO WE KEEP YOUR
Short: We aim to protect your personal information through a
system of organizational and technical security measures.
We have implemented appropriate technical and organizational
security measures designed to protect the security of any personal information we process.
However, please also remember that we cannot guarantee that the internet itself is 100% secure.
Although we will do our best to protect your personal information, transmission of personal
information to and from our
Apps is at your
own risk. You should only access the services within a secure environment.
7. WHAT ARE YOUR PRIVACY
In some regions, such as the European Economic Area,
you have rights that allow you greater access to and control over your personal
information. You may review, change, or
terminate your account at any time.
In some regions (like the European Economic Area), you have
certain rights under applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii) to request rectification
or erasure; (iii) to restrict the processing of your personal information; and (iv) if
applicable, to data portability. In certain circumstances, you may also have the right to
object to the processing of your personal information. To make such a request, please use
details provided below. We will
consider and act upon any request in accordance with applicable data protection
If we are relying on your consent to process your personal
information, you have the right to withdraw your consent at any time. Please note however
that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you
believe we are unlawfully processing your personal information, you also have the right to
complain to your local data protection supervisory authority. You can find their contact
details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights,
you may email us at [email protected].
If you would at any time like to review or change the
information in your account or terminate your account, you can:
Contact us using the contact information provided.
Upon your request to terminate your account, we will
deactivate or delete your account and information from our active databases. However, some
information may be retained in our files to prevent fraud, troubleshoot problems, assist
similar technologies: Most
Web browsers are set to accept cookies by default. If you prefer, you can usually choose to
set your browser to remove cookies and to reject cookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of our
opt-out of interest-based advertising by advertisers on our
Opting out of email
marketing: You can
unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in
the emails that we send or by contacting us using the details provided below. You will then
be removed from the marketing email list – however, we will still need to send you
service-related emails that are necessary for the administration and use of your account. To
otherwise opt-out, you may:
8. DATA BREACH
A privacy breach
occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal
information. You will be notified about data breaches when Heimo Solutions Oy
believes you are likely to be at risk or serious harm. For example, a data breach may be
likely to result in serious financial harm or harm to your mental or physical well-being. In the
event that Heimo Solutions Oy becomes aware of a security breach which
has resulted or may result in unauthorized access, use or disclosure of personal information Heimo Solutions Oy will promptly investigate the matter and notify the
applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the
personal data breach is unlikely to result in a risk to the rights and freedoms of natural
9. CONTROLS FOR DO-NOT-TRACK
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal
your privacy preference not to have data about your online browsing activities monitored and
collected. No uniform technology standard for recognizing and implementing DNT signals has
been finalized. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform
you about that practice in a revised version of this
10. DO CALIFORNIA RESIDENTS
HAVE SPECIFIC PRIVACY RIGHTS?
Short: Yes, if you are a resident of California, you are granted
specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the
“Shine The Light” law, permits our users who are California residents to request and obtain
from us, once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing purposes and the
names and addresses of all third parties with which we shared personal information in the
immediately preceding calendar year. If you are a California resident and would like to make
such a request, please submit your request in writing to us using the contact information
If you are under 18 years of age, reside in California, and have a
registered account with the
Apps, you have
the right to request removal of unwanted data that you publicly post on the
request removal of such data, please contact us using the contact information provided below,
and include the email address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the
please be aware that the data may not be completely or comprehensively removed from our systems.
11. DO WE MAKE UPDATES TO THIS
Short: Yes, we will update this policy as necessary to stay
compliant with relevant laws.
We may update this
from time to time. The updated version will be indicated by an updated
“Revised” date and the updated version will be effective as soon as it is accessible. If we make
material changes to this
, we may notify you either by prominently posting a notice of such changes or
by directly sending you a notification. We encourage you to review this
frequently to be informed of how we are protecting your
12. HOW CAN YOU CONTACT US
ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at [email protected]
HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to
request access to the personal information we collect from you, change that information, or delete
it in some circumstances. To request to review, update, or delete your personal information, please
visit: [email protected]
. We will respond to your request within 30 days.