This Privacy Policy is applicable to the personal data processed by Lobster.ist Oy ("Lobster.ist" or "we") relating to policymakers, their representatives and/or political assistants as well as public servants included in the Lobster.ist website and online platform ("Service") as part of providing the Service to the users. All of the aforementioned data subjects are hereinafter collectively referred to as “Policymaker” 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 Article 14 of the General Data Protection Regulation 2016/679 (GDPR).
Throughout this Privacy Policy the term “processing” is used to cover all activities involving your personal data, including collecting, handling, storing, accessing, using, transferring and disposing of information.
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 the Service users and the representatices of our vendors, business partners or customer organizations, please see our separate data protection description and privacy policy located at https://lobster.ist/privacy_policy.html. This policy shall also apply to you as a Policymaker to the extent you are acting under the capacity of a user of or visitor to the Service.
This Privacy Policy may be updated if required in order to reflect the changes in data processing practices or otherwise. We will not make substantial changes to this Privacy Policy or reduce your rights under this Privacy Policy without providing a notice thereof.
Lobster.ist Oy
Business ID: 2948426-4
Haahkatie 5 B 32
00200 Helsinki, Finland
We may collect the following type of personal information concerning you: name and contact details (such as email address and phone number), occupational position, public profiles on social media accounts, organization, CV, user notes from interactions with you, your direct correspondence with us concerning the Service, as well as project-specific notes.
Your personal information is collected and received exclusively from publicly available sources either maintained by the organisations in which you are holding a position of trust and/or your employer organisation, or, which you have expressed within the public sphere. The sources may include but are not limited to Parliament information services, competent authorities and social and conventional media.
Purposes of processing
To provide our Service (legal ground: legitimate interest)
We process your personal data to be able to offer the Service to our users and to run and maintain our 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 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 and legal processes. We may also process data for data, system and network security.
Legal grounds for processing
We primarily process your personal data based on our legitimate interest of providing our Service to the users. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy.
To the extent your personal information reveals your political opinions constituting therefore special category of personal data under article 9(1) of the GDPR, we shall in addition to our legitimate interest primarily rely on articles 9(2)(e) and/or 9(2)(f) of the GDPR.
Your personal information shall not be processed for the purposes of automated decision-making, including profiling.
Lobster.ist only stores, transfers or processes personal data only in the European Economic Area.
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.
To Service users
We share your personal data with our customers subscribed to the Service as users as well as visitors to the Service. Please note that any subsequent use of your personal data by our customers shall be subject to the privacy policies of the relevant customer organization.
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 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 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.
We will primarily store your personal data for the duration that you are in the public position relevant to the Service, unless we have legitimate grounds to process your personal data for a period longer than this in accordance with this Privacy Policy.
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.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 may object to the processing of personal data on grounds relating to your particular situation if such data are processed for our legitimate interest. In case we do not have compelling legitimate grounds to continue processing such personal data, we shall no longer process the personal data after your objection.
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.
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.
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.
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).
Lobster.ist Master Data Privacy Policy: June 8, 2023
This document is in connection to Lobster's Terms of Service.