1. Controller and Contact Information

Company: Digiverkosto Oy / Oskari Mikkola

Business ID: 3601658-1

Address: 31600 Jokioinen, Finland

Contact persons for privacy matters:

• Oskari Mikkola (toimisto@digiverkosto.fi, Phone: +358 45 107 4457)
• Aleksi Luhtasela (toimisto@digiverkosto.fi, Phone: +358 40 171 6579)

2. Collected Personal Data and Sources

We collect data from the following sources:

• Provided information: Name, email address, telephone number, company name, and other data voluntarily provided through forms (e.g., Facebook comments/messages, Facebook Lead Ads, or website forms). This data is managed in the HubSpot customer relationship management (CRM) system.
• Newsletter subscription: We collect email addresses and subscriber information in the Brevo service if a user subscribes to the newsletter and accepts this privacy policy.
• Automatic tracking (Cookies and tools):
  • Meta (Facebook): Meta Pixel, Conversions API, and advertising tools.
  • Google Analytics 4 (GA4): User analytics and site functionality.
  • Google Consent Mode v2: Transmission of consent information.
  • Microsoft Clarity: User experience analysis (mouse movements, clicks).

3. Purpose of Processing and Legal Basis

We process data for the following purposes:

• Customer relationship management, sales process management, communication, and service implementation.
• Targeting and profiling of marketing and advertising (Meta and Google).
• Sending newsletters and announcements.
• Website analytics and user experience development.

Legal basis: Processing is based on the user’s given consent, the performance of a contract, or the controller’s legitimate interest.

4. Data Sharing and Transfers

Data is disclosed or processed by the following service providers:

• HubSpot, Inc. – Customer relationship management and sales tracking. Data is stored on servers located within the European Union (EU).
• Brevo (Sendinblue SAS) (France/EU) – Email marketing management.
• Meta Platforms Ireland Limited (Ireland/USA).
• Google Ireland Limited (Ireland/USA).
• Microsoft Corporation (USA) – Microsoft Clarity analytics service.

If data is transferred outside the EU/EEA area (such as the USA), the level of data protection is ensured primarily by using the EU-U.S. Data Privacy Framework or standard contractual clauses (SCCs) approved by the European Commission.

5. Data Retention Period

We retain data only as long as necessary to fulfill the purposes defined in this policy or as required by legislation. Sales leads and customer data are retained in the HubSpot system as long as required for managing the customer relationship or completing a quote. Newsletter list data is retained until the user cancels their subscription.

6. Rights of the Data Subject

In accordance with the EU General Data Protection Regulation (GDPR), you have the right to inspect your data, request its rectification, deletion, or restriction of processing, and withdraw your consent at any time.

All requests related to rights must be sent to: toimisto@digiverkosto.fi.

7. Personal Data Register for Content Creators and Partners

Register name: Digiverkosto Partner and Recruitment Register.

Legal basis for processing:

• Implementation of pre-contractual measures (processing of applications).
• Performance of the contract (management of cooperation and payment of compensation).
• Legal obligation (storing accounting material).

Register data content:

• Identification details: Name, age, contact information (phone, email, address).
• Professional details: Work experience, portfolio, social media profiles, and potential billing information (Business ID or invoicing service).
• Media content: Introduction video provided by the applicant (contains image and audio recording).

Regular data sources: Information is collected directly from the data subject themselves via a website form, a Tally.so form, or by email.

Regular disclosures and transfer of data outside the EU or EEA:

• Data is stored on a WordPress server managed by Digiverkosto (EU).
• Video files and responses are stored in the Tally.so system.
• Contact information and the status of the application process can be managed in the HubSpot system.
• Video files are not disclosed to third parties. If a service provider (such as Tally.so or HubSpot) transfers data outside the EU/EEA, EU standard contractual clauses (SCCs) or the Data Privacy Framework are used.

Principles of register protection:

• Manual material: None stored.
• Digital material: Access to data is restricted only to persons responsible for recruitment and partnerships using personal usernames. The website, Tally.so, and administrative systems used are protected with appropriate encryptions.