Privacy Policy

Digital Network Ltd. Updated 19.10.2026.

This privacy policy explains how Digiverkosto Oy collects, processes and protects personal data when you visit our website, contact us or use our services.

1. Data controller and contact persons

Company: Digital Network Ltd / Oskari Mikkola

Business ID: 3601658-1

Address: Hakalantie 4, 31600 Jokioinen

Offices:

Aleksi Luhtasela, Veteli
Oskari Mikkola, Jokioinen

Contact persons for data protection matters:

Oskari Mikkola, toimisto@digiverkosto.fi, tel. +358 45 107 4457
Aleksi Luhtasela, toimisto@digiverkosto.fi, tel. +358 40 171 6579

2. Personal data collected and sources

We collect information from the following sources.

Self-provided information: name, email address, phone number, company name, and other information you voluntarily provide through forms. These include Facebook comments and messages, Facebook Lead Ads, and website forms. This information is managed in the HubSpot customer relationship management (CRM) system.

The website's contact and quote forms forward messages to our email via the FormSubmit service.

Newsletter: if you subscribe to the newsletter, we process your email address and subscriber information. Newsletters are sent via the Brevo service.

Customer work information: quotes, contracts, email correspondence, schedules, and meeting notes when a note-taking assistant is used in the meeting.

Public company information: company name, industry, and contact person name and work contact information from public company registers and companies' own websites. We only use this when we are looking for companies that could benefit from our services (see section 3).

Calendar: Apple iCloud Calendar stores only the information necessary to manage your schedule.

Automatic tracking (cookies and tools) is only enabled with your consent. Consents are managed with the CookieYes service. More detailed information can be found in our cookie policy: https://digiverkosto.fi/evasteet/

Meta (Facebook): Meta Pixel, Conversions API and advertising tools.
Google Analytics 4 (GA4): user analytics and site activity.
Google Consent Mode v2: transmission of consent information.
Microsoft Clarity: user experience analysis, such as mouse movements and clicks.

3. Purpose and legal basis of processing

We process data for the following purposes:

Customer relationship management, sales process management, communication and service implementation. The legal basis is a contract or pre-contractual measures.
Marketing and advertising targeting and profiling (Meta and Google). The legal basis is the consent you provide in the cookie settings.
Sending newsletters and announcements. The legal basis is consent, which you can withdraw at any time.
Website analytics and user experience development. The legal basis is consent through cookie settings.
Mapping of potential corporate customers. We search for companies that could benefit from our services in public sources and contact them. We only process work-related contact information. The basis is our legitimate interest in marketing our services to other companies. You can object to the use of your information for this purpose at any time, and we will remove it from our lists. All you have to do is reply to our message or send a message to toimisto@digiverkosto.fi.
Maintenance of customer websites. Depending on the maintenance of the website, we either act as a processor of personal data on behalf of the customer or the customer is responsible for the maintenance themselves. Responsibility and roles are determined by agreement.
Accounting and invoicing. The legal basis is a statutory obligation.

4. Data sharing and transfers

We do not sell your information. Your information is shared with or processed by the following service providers:

HubSpot, Inc.: customer relationship management and sales tracking. Data is stored on servers located in the European Union (EU).
Brevo (Sendinblue SAS), France/EU: email marketing management.
FormSubmit (formsubmit.co): forwards messages from website contact and offer forms to our email. According to its terms, FormSubmit does not collect personal data from the form for its own use, but forwards it to us.
CookieYes: cookie consent management.
Hostinger International Ltd, Cyprus: website maintenance, company email (including aleksi@digiverkosto.fi and toimisto@digiverkosto.fi), and backups. The data center is located in Lithuania (EU). Hostinger deletes old automatic backups itself. Backups taken by yourself are kept for as long as they are needed.
Meta Platforms Ireland Limited, Ireland/USA: advertising, Meta Pixel, Conversions API and advertising tools.
Google Ireland Limited, Ireland/USA: Google Analytics 4, advertising and, if necessary, website appointment booking, as well as storage of offers and project documents (Google Drive and Docs). We use a personal Google account, not Google Workspace, so Google's standard terms of use and privacy policy apply. The service provider for users in the EEA is Google Ireland Limited. Data may also be processed on the servers of the parent company Google LLC in the USA.
Microsoft Corporation, USA: Microsoft Clarity analytics.
Apple Distribution International Ltd, Ireland: iCloud Calendar for schedules and reminders. Calendar stores only the information necessary for this purpose.
Fireflies.ai (Fireflies.AI Corp., USA): Transcribes and summarizes Teams calls when a note-taking assistant is in use. We inform participants at the beginning of the call that a note-taking assistant is present. Wording may vary. Data is processed in the United States. Fireflies is a party to the EU–US Data Privacy Framework and does not use data to train AI models or allow its subcontractors to do so.
Anysphere, Inc. (Cursor), USA: an artificial intelligence assistant that only suggests things to Digiverkosto employees. More specifically in section 7. A personal account is in use, so Cursor's separate data processing agreement does not apply to it. Cursor's privacy mode is on, so according to Cursor's instructions, the data is not used to train Cursor's models.

If data is transferred outside the EU or EEA (such as the United States), the level of data protection is ensured primarily by using the EU–US Data Privacy Framework or the Standard Contractual Clauses (SCC) approved by the European Commission. For Cursor, transfers are based on Cursor's Privacy Policy and its stated lawful transfer grounds, as there is no separate data processing agreement for the personal account.

5. Data retention period

We only retain information for as long as necessary to fulfill the purposes set out in this statement or as required by law.

Sales leads and customer data are retained in the HubSpot system for as long as required to manage the customer relationship or complete the offer.
Newsletter list information is retained until the user cancels their subscription.
Contracts, offers and other documents are stored securely for as long as necessary. Contracts containing personal data are stored in a way that prevents them from being accessed unnecessarily.
Hostinger deletes old automatic backups itself. Manual backups are kept for as long as they are needed.
Business contact information collected from public sources is retained for as long as it is needed and deleted when the information is no longer needed or if you object to its use.
Accounting records are retained for the period specified in the Accounting Act.

6. Rights of the data subject

Under the EU General Data Protection Regulation, you have the right to:

check your information
request their correction or deletion
request restriction of processing
object to processing based on legitimate interest and prohibit direct marketing at any time
receive the information you have provided in a machine-readable format and transfer it to another service provider
withdraw your consent at any time
lodge a complaint with a supervisory authority if you believe that your data is being processed unlawfully. In Finland, the authority is the Office of the Finnish Data Protection Commissioner, www.tietosuoja.fi.

All requests related to rights should be sent to toimisto@digiverkosto.fi. We will respond within one month at the latest.

7. Artificial intelligence as part of our work

We use an artificial intelligence assistant (Cursor) to help us in our everyday work. The assistant only suggests things to Digiverkosto employees. A human checks what is sent to the customer. We do not use artificial intelligence to make automatic decisions that would have legal or other significant effects on you. If you request it, we will handle your case completely without artificial intelligence. Let us know about it at toimisto@digiverkosto.fi.

The assistant helps with these tasks:

Email: reads incoming messages and prepares draft responses. Messages are sent by a human. The assistant does not send messages to customers on their own.
Website maintenance: helps update and maintain our clients' WordPress websites. The site is backed up before the update.
Offers and Projects: helps prepare and organize offers and project documents.
Schedules: helps with calendar entries and reminders.
Meetings: reads summaries made by the Fireflies service and extracts the agreed tasks from them.
Finding new customers: gather publicly available business information (see section 3).

Cursor's Privacy Mode is enabled. According to Cursor's instructions, the data is not used to train Cursor's models. There are zero-retention agreements with the model providers. The assistant service is provided by Anysphere, Inc., a US company. Data may be processed in the US and transferred to the provider of the selected artificial intelligence model, such as OpenAI, Anthropic or Google. An up-to-date list of subprocessors can be found at trust.cursor.com/subprocessors. Transfers outside the EU or EEA are protected as described in section 4.

8. Information security

Access to data is limited to those who need it for their work with personal usernames. The services we use are protected with encrypted connections. Backups are taken of customer websites before updates. Contracts containing personal data are stored with limited access. Two-factor authentication is used in all services that store personal data.

9. Personal data register of content producers and partners

Legal basis for processing:

Implementation of pre-contractual measures (application processing).
Contract implementation (cooperation management and commission payment).
Legal obligation (retention of accounting records).

Data content of the register:

Identification information: name, age, contact information (phone, email, address).
Professional information: work experience, portfolio, social media profiles and possible billing information (business ID or billing service).
Media content: introductory video (image and audio recording) submitted by the applicant.

Regular data sources: data is collected directly from the data subject via a website form or email.

Data transfers and transfers outside the EU or EEA:

The data is stored on a server managed by the Digital Network in the EU.
Video files are not disclosed to third parties. If the service provider transfers data outside the EU or EEA, the EU-US Data Privacy Framework or the Standard Contractual Clauses (SCC) approved by the European Commission are used.

Register protection: no manual data is stored. Access to digital data is limited to those responsible for recruitment and partnerships. Access requires personal credentials, and connections are protected by encryption.

10. Digital Network Customer Portal

We offer our customers the Digiverkost Customer Portal, through which the customer can manage their order, view the status of their website, utilize additional services at discounted prices, send support requests, and manage the benefits of the referral program.

Information collected and registration: You log in to the portal with your own credentials. The service uses the Ultimate Member system, which processes usernames, email addresses and login information. We also use the browser's local memory (localStorage) as well as URL identifiers to remember the state of the active tab to maintain a smooth user experience.
Purpose and legal basis of processing: Providing a customer portal and technical maintenance of the customer relationship. The legal basis is a valid customer agreement and its implementation.
Data retention period: The customer portal's credentials and related user data are retained as long as the customer relationship and agreement are valid, or until the customer requests closure of their account.

11. Changes to the description

We will update this statement when our operations or the services we use change. The most up-to-date version is always on this page. This statement was last updated on 19.10.2026.