1.2 Owner of LIFETIMELY. LIFETIMELY is owned and operated by Lifetimely Oy having a registered office at Lauttasaarentie 27 A3, 00200 Helsinki, Finland, and the company registration number 3107222-6 (“we”, “us”, or “our”).
1.3 Our role as a data controller and data processor. We act in the capacity of a data controller and a data processor with regard to the personal data processed through LIFETIMELY in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is handled by us, as explained in detail below:
1.5 Minors. LIFETIMELY is not intended for use by children (i.e., persons who are minors in their country of residence). Therefore, we do not knowingly collect minors’ personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay.
2.2 Sensitive data. We do not collect or have access to any special categories of personal data as defined by Art. 9 of the GDPR (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation. If Your Data contains the said sensitive data, we will process such data for the purpose of fulfilling our contractual obligations.
2.3 Processing of Your Data. When you upload or create Your Data on LIFETIMELY, we process Your Data as requested by you, including any personal data Your Data may contain. Your Data may contain the following information: your customers’ email addresses and countries, information about your customers’ orders and refunds, and analytics data related to your online store (e.g., as generated by Google Analytics). We process Your Data in order to (i) provide you with the requested services and (ii) perform our contractual obligations. The legal basis on which we rely is ‘performing a contract with you’.
2.4 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to use the full functionality of LIFETIMELY or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
2.5 Sources of personal data. We obtain your personal data from the following categories of sources:
3.1 Log files and analytics data. In order to analyse your use of LIFETIMELY, we and our analytics service provider Google Analytics automatically collects certain technical non-personal data about your use of LIFETIMELY. Such data does not allow us us to identify you as an individual person in any manner. The non-personal data includes the following information:
3.2 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records.
3.3 Purposes of technical (non-personal) data. We use your technical (non-personal) data for the following purposes:
3.4 Aggregated and de-identified data. If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.
4.1 Newsletters. If we have your email address, we may, from time to time, send you a newsletter informing you about the latest developments related to LIFETIMELY and our special offers. You will receive our newsletters in the following instances:
4.2 Opting-out. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters, adjusting the settings of your user account, or by contacting us directly.
4.3 Tracking pixels. The newsletters sent by us may contain tracking pixels that allow us to conduct analysis of our marketing campaigns. Tracking pixels allow us to see whether you opened the newsletter and what links you have clicked on. We use such information to conduct analytics and pursue our legitimate business interests.
4.4 Service-related notices. If necessary, we will send you important informational messages, such as confirmation receipts, payment information, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
5.3 Retention as required by law. In certain cases, we are required by law to store your personal data for certain period of time (e.g., for business records or accountancy purposes). Thus, we keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires.
6.1 Disclosure to data processors. From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:
6.3 Disclosure of technical (non-personal) data. Your technical (non-personal) data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving LIFETIMELY, responding to lawful requests from public authorities or developing new products and services.
6.4 Legal requests. If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
6.7 International transfers. Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.
7.1 Our security measures. We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include:
7.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
8.1 The list of your rights. You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):
8.3 Complaints. If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
8.4 Non-discrimination. We do not discriminate you if you decide to exercise your rights. It means that we will not (i) deny any goods and services, (ii) charge you different prices, (iii) deny any discounts or benefits, (iv) impose penalties, or (v) provide you with a lower quality services.
Postal address: Lifetimely Oy, Lauttasaarentie 27 A3, 00200 Helsinki, Finland