EFFECTIVE FROM 1.2.2020

1. Controller and contact person
2. Introduction
3. The Data Collected by Vallox
4. Purposes of Use of Data
5. Disclosure of Data
6. Your Rights
7. Data Security
8. Transfers of Personal Data Outside EU / EEA // International Transfers of Personal Data
9. Children’s Privacy
10. Changes to The Privacy Policy
11. Questions or Concerns?
    

1 CONTROLLER AND CONTACT PERSON

Vallox Oy Business I.D. FI06723509 Myllykyläntie 9, 32200 Loimaa, Finland (“Vallox”, “we”, “us” or “our”)
Contact person in matters related to the processing of personal data: Vallox Info, Vallox Oy, Myllykyläntie 9, 32200 Loimaa, Finland +358 10 7732 200 Info@Vallox.com

2 INTRODUCTION

Vallox considers the privacy and the protection of personal data are very important elements of the user experience of myvalloxcloud.com and of any related services or applications (the “Service”), as described in our Terms of Service.

In this Privacy Policy, the term “personal data” means information that relates to an identified or identifiable natural person, which we collect to our client register. This Privacy Policy tells you about the ways in which Vallox protects your privacy and your personal data that Vallox processes.

Vallox acknowledges that you as the user of the Service are concerned about how Vallox uses and discloses your personal data. Vallox is dedicated to openness regarding the ways in which Vallox uses and discloses any personal data, and Vallox is committed to complying with data protection and privacy laws that apply to it. Importantly, Vallox wants to give you control over the personal data about you that Vallox processes when you use the Service.

Vallox may use third-party service providers for the processing of personal data in relation to offering the Service to you.

Vallox would like to remind you that this Privacy Policy applies to personal data that Vallox process when you use the Service. It does not apply to any links to third parties’ websites and/or services that you may encounter when you use the Service. Vallox kindly encourages you to carefully familiarize yourself with the respective privacy policies applicable to any websites and/or services operated by third parties. Please be aware that Vallox is not responsible for the privacy practices of any such third parties.
By using the Service, you accept the privacy practices described in this Privacy Policy.

3 THE DATA COLLECTED BY VALLOX

The personal data is primarily collected from you as information voluntarily provided to us, but may also be collected from external sources or through automated means. In Section 2 we describe in detail the personal data we collect.
3.1 Data that you provideVallox may collect the following information from its users (“Users”, “you”) that may, in certain circumstances, constitute following personal data:

• E-mail address;
• Password;
• First name;
• Last name;
• Language;
• Country;
• Company.

3.2 Data provided by other sources

Vallox may also collect personal data, where lawful to do so, from public sources and third-party service providers.

3.3 Automatically collected data

The Service may automatically collect the following information from Users of the Service that in certain circumstances may constitute personal data:

• Countries by usage;
• Languages by usage.

Moreover, details of transactions you carry out through the Service, and details of your visits to the Service including, but not limited to, traffic data and other communication data may also be collected by Vallox.

4 LEGAL BASES FOR PROCESSING AND PURPOSES OF USE OF DATA

Legal grounds for processing your personal data are either compliance with the agreement entered into between us, compliance with legal obligations to which we are subject, our legitimate interest, or your consent as further described below.

• Contractual and statutory obligations: Processing of your personal data to a certain extent is necessary to enable us to fulfill the agreement we have concluded with you. For example, when you enter into an agreement with us and/or use our services, it is necessary for us to process your personal data so that we can carry our contractual obligations to provide you the services. This also creates certain statutory obligations for us related to e.g. product safety.
• Our legitimate interest: We process your personal data based on our legitimate interest, in particular, to offer you first-class customer experience related to our Service and to provide you the most relevant online and newsletters content as well as for administrative purposes and to preventing and resolving possible misconduct.
• Consent: Based on your consent, we can process your personal data to sending you electronic direct marketing.

The provision of your personal data as described in this Privacy Policy is partially a contractual requirement. For example, when you enter into an agreement with us or register to the Service, you are required to provide us with certain personal data for processing purposes specified in this Privacy Policy. Failure to provide us personal data may prevent us from performing our contractual obligations, which may lead to you being unable to use the Service.

Vallox uses the collected data described in Section 3 for the following purposes:

• To manage and develop the client relationship;
• To provide and develop the Service;
• To prevent and investigate fraud and other misuses;
• To protect rights of Vallox and/or property of Vallox;
• To operate and improve the products and services of Vallox;
• For analytics and statistics;
• For other comparable purposes.

5 DISCLOSURES OR TRANSFERS OF DATA

Vallox does not sell, lease, rent or otherwise disclose or transfer the personal data relating to our Users to third parties unless otherwise stated below in this Section 5.

The personal data collected in, through or from the Service may be disclosed to the following categories of third parties in the following situations:

• To service providers, such as payment processors enabling Vallox to provide the Service to you;
• To public authorities, such as law enforcement if Vallox is legally obliged to so or if Vallox is required, or in need to, protect its rights or the rights of third parties; and
• To the subsidiaries and affiliates of Vallox; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, acquisition, consolidation, restructuring, or the sale of substantially all of the stock and/or assets of Vallox, bankruptcy, or other corporate reorganization, in accordance with this Privacy Policy.

We use partners, whether affiliated or unaffiliated, in providing the Service. We transfer your personal data to these parties, called data processors, to process such data as necessary for the specified purposes of the processing. Such processing conducted by data processors may include in particular provision of technical support to us, storing of data or other corresponding automated data processing activities. For the sake of clarity, Vallox may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual Users of the Service.

6 YOUR RIGHTS

If you have declared your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

You also have the right to lodge a complaint with the competent data protection supervisory authority regarding our processing of personal data. For such complaints, please follow the instructions provided by the competent supervisory authority.

Pursuant to applicable data protection laws you may have the following rights with respect to the personal data Vallox holds about you:

6.1 The right to know the content and extent of data Vallox holds about you

If you would like to know what personal data Vallox holds about you, you can approach Vallox with a written request by using the contact details at the beginning of this Privacy Policy. Vallox is committed to responding swiftly to your possible inquiry.

Please consider that Vallox reserves the right to charge a small processing fee if less than twelve (12) months have passed since your last inquiry relating to personal data Vallox holds about you.

6.2 The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, deleted, or updated

The easiest way to correct, delete, or update the personal data you have provided to the Service is to log in to the Service and enter the necessary changes there. If you have additional questions regarding the correction, deletion, or updating of the personal data Vallox holds about you, please contact Vallox by using the contact details at the beginning of this Privacy Policy.

6.3 Right to be forgotten

You as a data subject also have the right at any time to request us to erase personal data concerning you and processed by us and we are obliged to erase the data if there is no longer a legal ground for processing the data. Please note that certain data processed by us may be subject to statutory retention requirements, and regardless of a request of erasure, such data we cannot erase until the end of the applicable statutory retention period.

For requests related to the erasure of your data, please contact us by using the contact details at the beginning of this Privacy Policy.

6.4 Right to restriction of processing

Under certain circumstances, you may have the right to obtain from us restriction of processing of your personal data. Should the restriction of processing apply, the respective personal data will be marked and may only be processed by us for certain defined purposes.

6.5 Right to data portability

Under certain circumstances, you may have the right to receive such personal data that you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another entity without hindrance from us.

For requests related to your right to data portability, please contact us by using the contact details at the beginning of this Privacy Policy.

6.6 The right to opt-out of receiving electronic direct marketing communications from Vallox

All electronic direct marketing communications that you may receive from Vallox, such as e-mail messages and SMS-messages, give you the option of not receiving such communications from Vallox in the future. If you have any additional questions about electronic direct marketing received from Vallox, please contact Vallox by using the contact details at the end of this Privacy Policy.

7 DATA SECURITY

Vallox has taken and is committed to maintaining appropriate technical and organizational measures to protect personal data from unauthorized access or against loss, misuse or alteration by third parties. Despite these efforts to store personal data collected in and through the Service in a secure operating environment that is not available to the public, Vallox cannot guarantee the security of personal data during its transmission or its storage in the systems of Vallox. Furthermore, while Vallox attempts to ensure the integrity and security of personal data, Vallox cannot guarantee that its security measures will prevent third-parties such as so-called hackers from illegally obtaining access to the personal data. Vallox does not warrant or represent that personal data about you will be protected against loss, misuse, or alteration by third parties.

8 TRANSFER OF PERSONAL DATA OUTSIDE EU / EEA // INTERNATIONAL TRANS-FERS OF PERSONAL DATA

Vallox does not transfer any personal data outside EU/EEA.

9 RETENTION TIME OF PERSONAL DATA

The retention time of the collected personal data is subject to the legal basis and processing purpose for which the data were collected. We will retain your personal data for as long as they are necessary for carrying out the processing purposes specified in the Privacy Policy, such as the fulfillment of our contractual obligations (e.g. return and limited warranty periods), or for providing other customer services. When we no longer need the collected personal data, the data will be safely destroyed or irrevocably anonymized.

The retention periods for personal data are determined in accordance with the following criteria:

• Your personal data will be retained for as long as the agreement between you and us is in force;
• Related personal data will be retained for as long as the legitimate interest of us can reasonably be considered valid. The validity of our legitimate interest is determined by, for example, the use of our Service and the communication between you and us, such as customer service communications.
• Related personal data will be deleted when you withdraw your consent or object to the processing of your personal data for direct marketing purposes. In this case, however, we may keep the information regarding your objection to receiving direct marketing.

10 RELATED PERSONAL DATA WILL BE DELETED WHEN YOU HAVE REQUESTED THE ERASURE OF YOUR DATA AND THERE IS NO LONGER A LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA. CHANGES TO THE PRIVACY POLICY

Vallox may, from time to time, change this Privacy Policy. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend at the top of this page. Vallox encourages you to review this Privacy Policy regularly for any changes. If Vallox will materially change the ways in which Vallox uses and discloses personal data, Vallox will post a notice in the Service and send an e-mail to our registered Users. Your continued use of the Service following any changes to this Privacy Policy constitutes your acceptance of any such changes made.

11 QUESTIONS OR CONCERNS?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Service, or the protection of the personal data Vallox holds about you, please contact us by using the contact details mentioned at the beginning of this Privacy Policy. Vallox always seeks to swiftly resolve any concerns you may have concerning its Service or the Privacy Policy of the Service.