Lobster – Privacy Policy

This Privacy Policy is applicable to the personal data processed by Lobster.ist Oy (“Lobster.ist” or “we”) relating to the users of the Lobster.ist website and online platform (“Service”). This Privacy Policy is also applicable to personal data processed by Lobster.ist in regard to the representatives of our vendors, business partners or customer organizations, including personal data processed within our CRM databases or in connection to our marketing activities. All of the aforementioned data subjects are hereinafter collectively referred to as “Users” or “you.”

The purpose of this Privacy Policy is to provide you with information about the processing of your personal data in accordance with the information obligations set in Articles 13 and 14 of the General Data Protection Regulation 2016/679 (GDPR).
Please note that this Privacy Policy only applies to our processing of personal data of the above mentioned data subjects where we act as a data controller. This Privacy Policy does not address, and we are not responsible for, the privacy and data processing practices of any third parties.

In regard to our processing of personal data of policymakers, please see our separate data protection description and privacy policy located at https://lobster.ist/privacy_policy_masterdata.html.

This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. The current version can be found on our website https://lobster.ist/website_privacy_policy.html. We will not make substantial changes to this Privacy Policy or reduce your rights under this Privacy Policy without providing a notice thereof.

CONTACT DETAILS
Lobster.ist Oy
Business ID: 2948426-4
Haahkatie 5 B 32
00200 Helsinki, Finland
info@lobster.ist
lobster.ist

PERSONAL DATA PROCESSED AND SOURCES OF DATA

We collect two types of information concerning our Users: (i) User Data; and (ii) Analytics Data.
User Data is primarily received directly from you either in connection to your use of the Service or in connection to your interaction with us. In certain cases it may also be provided to us by the company or organization on behalf of which you are using the Service.

Analytics Data is collected automatically as you use the Service. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with other data. In such situations, Analytics Data shall also be considered to be personal data under applicable laws and we will treat the combined data as personal data.

User Data and Analytics Data typically consist of the following categories of data:

User Data
• Username, password and other credentials;
• Name;
• Contact information (such as email address and phone number)
• Organisation and work title;
• Service settings and preferences;
• Metadata relating to your use of the Service;
• Any direct correspondence with Lobster.ist;
• Direct marketing opt-outs and opt-ins.

Analytics Data
• Anonymized partial IP address;
• Device type and model (computer, phone or tablet);
• Operating system;
• Time of visit;
• Browser type and version;
• Language settings.

COOKIES AND ANALYTICS TOOLS

We don’t use cookies or social media trackers on our public web site.

We use self hosted Matomo Analytics Analytics Data and reports on visitor usage. For an overview of Matomo Analytics, please visit Matomo web site. We don’t store any identifying information for individual users for our analytics. We respect Do Not Track settings for web site visitors.

PURPOSES AND LEGITIMATE GROUNDS OF PROCESSING

Purposes of processing
To provide our Service and carry out our contractual obligations (legal ground: performance of a contract and legitimate interest)
We process personal data to be able to offer the Service to our Users and to run and maintain our business. Personal data may be processed in order to carry out our contractual obligations towards the User or towards the organization the User represents. We may use the data for example to offer essential functionalities of the Service and to provide access to the Service.

For our legal obligations (legal ground: compliance with a legal obligation)
We process personal data to enable us to administer and fulfil our obligations under law. This includes data processed for complying with our bookkeeping obligations and providing information to relevant authorities.

For claims handling and legal processes (legal ground: legitimate interest)
We may process personal data in relation to claims handling, debt collection and legal processes. We may also process data for the prevention of fraud, misuse of our services and for data, system and network security.

For communication and marketing (legal ground: legitimate interest)
We may process personal data for the purpose of contacting our Users regarding our Service and for informing Users of changes in our Service. We may also process personal data to market our Service, for example in the form of sending newsletters.

For quality improvement and trend analysis (legal ground: legitimate interest)
We may process information regarding your use of the Service to improve the quality of our service, for example by analysing any trends in the use of our Service. Where possible, we will do this using only aggregated, non-personally identifiable data.

Legal grounds for processing

We primarily process personal data on a contractual basis. For individuals acting as representatives of our customer or partner organizations, personal data is primarily processed based on our legitimate interest whilst fulfilling our contractual obligations towards the organisations they represent.

We may also process personal data based on our legitimate interests, for example in connection with analytics and marketing. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.

In certain cases you may be requested to grant your consent for the processing of your personal data. In this event, the legal ground for such processing is your consent. You may withdraw your consent at any time.

INTERNATIONAL TRANSFERS

Lobster.ist only stores, transfers or processes personal data only in the European Economic Area, Andorra, Switzerland and the UK. All of which are either regulated by GDPR or deemed to have adequate level of data protection by the European Union.

PERSONAL DATA RECIPIENTS

We do not share personal data with third parties outside of the Lobster.ist organization unless one of the following circumstances applies:
It is necessary for the purposes set out in this Privacy Policy
To the extent that third parties need access to personal data to ensure the performance fo the Service, Lobster.ist has taken appropriate contractual and organisational measures to ensure that personal data are processed exclusively for the purposes specified in this Privacy Policy and in accordance with all applicable laws and regulations.
For legal reasons
We may share personal data with third parties outside of our organization if we have a good-faith belief that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of Lobster.ist, our Users or the public in accordance with the law. When possible, we will inform you about such transfer and processing.
To authorized service providers
We may share personal data to authorized service providers who perform services for us (including data storage, sales, marketing and support services). Our agreements with our service providers include commitments that the service providers agree to limit their use of personal data and to comply with privacy and security standards at least as stringent as the terms of this Privacy Policy.
For other legitimate reasons
If Lobster.ist is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to those concerned when the personal data are transferred or become subject to a different privacy policy as soon as reasonably possible.
With explicit consent
We may share personal data with third parties outside of our organization for other reasons than the ones mentioned before, when we have your explicit consent to do so. You have the right to withdraw this consent at all times.

STORAGE PERIOD

Lobster.ist does not store personal data longer than is legally permitted and necessary for purposes of providing the Service or the relevant parts thereof, or for another individual purpose for which your personal data is being processed. The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
We will store Analytics Data relating to the Service no longer than reasonably necessary. We regularly review and assess the storage periods of Analytics Data and erase or anonymize Analytics Data when we no longer need it for the purposes for which it was collected.

YOUR RIGHTS

Right to access
You have the right to access your personal data processed by us. You may contact us and we will inform what personal data we have collected and processed regarding you.
Right to withdraw consent
In case the processing is based on a consent you have granted to us, you may withdraw the consent at any time. Withdrawing a consent may lead to fewer possibilities to use our Service. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed by contacting us.
Right to erasure
You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You have the right to object to certain use of your personal data if such data are processed for other purposes than necessary for the performance of the Service or for compliance with a legal obligation. If you object to the further processing of your personal data, this may lead to fewer possibilities to use the our Service.
Right to restriction of processing
You may request us to restrict processing of personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may however lead to fewer possibilities to use our Service.
Right to data portability
You have the right to receive your personal data from us in a structured and commonly used format and to independently transmit those data to a third party.
How to use the rights
The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity.
We reserve the right to reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

DIRECT MARKETING

Notwithstanding any consent granted beforehand for the purposes of direct marketing, you have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.

INFORMATION SECURITY

We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Our security controls are designed to maintain an appropriate level of data confidentiality, integrity, availability, resilience and ability restore the data. We regularly test our systems, and other assets for security vulnerabilities.

Should despite of the security measures, a security breach occur that is likely to have negative effects on your privacy, we will inform you and other affected parties, as well as relevant authorities when required by applicable data protection laws, about the breach as soon as possible.

LODGING A COMPLAINT

In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.

In Finland, the local supervisory authority is the Data Protection Ombudsman (https://www.tietosuoja.fi).
Privacy Policy Effective Date: January 24, 2022