Privacy Policy

SelectAM Oy, a private limited company registered under the laws of Finland registration code 3162647-9, registered address Lapinlahdenkatu 16, 00180 Helsinki, Finland (“SelectAM", “we” or “us”) is committed to respecting and safeguarding your privacy rights and complying with applicable data protection regulations.

This Privacy Policy describes the general principles of Personal Data processing activities carried out by SelectAM, your rights with respect to your Personal Data and how we process it through your use of selectam.io and https://app.selectam.io (collectively the “Platform”) and services and other interactions you may have with us that are subject to this Privacy Policy (collectively referred to as our “Services“).

If you have inquiries regarding the handling of your Personal Data or if you want to make requests related to the rights associated with the processing of your Personal Data, kindly reach out to us using the contact details specified at the end of this Privacy Policy.

1.) DEFINITIONS

For the purposes of this Privacy Policy, the following capitalised terms shall have the following meanings:

“Applicable Laws”	means all applicable data protection laws, including but not limited to the European Union’s General Data Protection Regulation 2016/679, the Finnish Data Protection Act (1050/2018), the United Kingdom’s Data Protection Act of 2018 along with the UK GDPR as retained as UK law by the European Union Withdrawal Act 2018 and California Consumer Privacy Act as amended by the California Privacy Rights Act (collectively “CCPA”).
“Data Subject”	means a natural person whose Personal Data is processed by SelectAM. In the context of this Privacy Policy, “Data Subject”, and “You” are used interchangeably.
“GDPR”	means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
“Personal Data”	means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Platform”	means the platform available at https://selectam.io
“Data Controller”	means a natural or legal person, public sector authority, agency or other body who, alone or jointly with others, determines the purposes and means of the Personal Data processing.
“Data Processor”	means a natural or legal person, public sector authority, agency or other body who processes the Personal Data on behalf of the controller.

2.) HOW WE OBTAIN PROCESS Personal Data AND WHAT Personal Data DO WE PROCESS?

2.1 We may collect and process different types of Personal Data in the course of operating our Platform and providing our Services. In the course of processing activities, we may obtain the Personal Data either directly from you or through your usage of our Platform (via cookies, for example).

2.2 Upon the use of our Platform, we process Personal Data that is submitted to us directly by you in the course of using our Platform. Such data includes the following:

a. Contact Data: such as name (first and last name), company email address, phone number and affiliation in a certain company;

b. Login Data: such as login details and information (for example, password) used for creating account via Platform;

c. Technical Data: such as technical information collected in the course of your use of the Platform, for example the operating system of your device and other data collected via cookies (please read more about cookies in the section 5 below).

3.) WHAT IS THE LEGAL BASIS FOR PROCESSING Personal Data?

3.1 GDPR requires us to inform you of our legal bases for processing your Personal Data. Our legal basis will depend on the particular category of Personal Data and the specific context in which we collect it. However, below are some examples of legal bases for processing that we rely on.

3.2 For the performance of a contract (Article 6(1)(b) of the GDPR). SelectAM processes Personal Data primarily for the purposes of performing our contractual obligations that arise from Terms of Use.

3.3 For the performance of a legal obligation (Article 6(1)(c) of the GDPR). SelectAM may process Personal Data also where it is required to perform legal obligations applicable to us. For example, when the use of your Personal Data is necessary to comply with our legal obligations to collect and store tax or invoice information for a certain period of time or if a court requests Personal Data from SelectAM under an applicable court order or court judgement or if a law enforcement agency requests Personal Data under an applicable regulation.

3.4 On the basis of legitimate interest (Article 6(1)(f) of the GDPR). SelectAM may process your Personal Data also when it is necessary for SelectAM’s legitimate interest in certain cases. We process Personal Data on the basis of legitimate interest only in case such processing is not outweighed by the basic rights and freedoms of the data subject for which the Personal Data must be protected.

3.5 On the basis of consent (Article 6(1)(a) of the GDPR). Where we have your consent to process data in a certain way (for example, for cookies or when you contact us for a free demo trial).

3.6 Here is a summary outlining the purposes, categories, and duration of data retention for the processing activities.

Purpose	Legal basis	Collected Personal Data	Examples of retention period
Providing Services through the Platform	GDPR Article 6 (1) (b), after the termination of the contract GDPR Article 6 (1) (f)	Contact details: name, e-mail address, telephone number and company affiliation.	storing information related to your agreement with us for up to 3 years after end of customer relationship
Answering the inquiries of the Data Subject	GDPR Article 6 (1) (f)	Name, e-mail and other Personal Data that is submitted to us directly by you via Platform or via any other channel (for example, by sending an e-mail).	Will be retained until the end of the limitation period associated with the claim in question. Typically for up to 2 years.
Accounting documents	GDPR Article 6 (1) (c)	Personal Data collected through invoices or other documents required for the performance of a legal obligation.	for up to 6 years
Providing user’s login to their accounts	GDPR Article 6(1)(b)	Account related details: login details and password selected for the account.	For user logins, the current retention period is set at 1 day. Regarding user profiles, they will be retained as long as users remain active.
Chatbot	GDPR Article 6(1)(b)	Personal Data obtained through a chatbot, including but note limited to full name, email address, phone number and job title.	We use this for communication purposes such as help requests, signing up for plans, event registrations, newsletters etc., and tracking how you are interacting with our Platform.
Data collected with cookies	We use this for communication purposes such as help requests, signing up for plans, event registrations, newsletters etc., and tracking how you are interacting with our Platform

4.) WHO DO WE SHARE YOUR PERSONAL DATA WITH?

4.1 SelectAM does not transfer Personal Data to third parties, except when SelectAM has the legitimate right under the applicable laws. SelectAM does not transfer Personal Data outside the European Economic Area.

4.2 SelectAM may engage specific Data Processors to handle the processing of Personal Data. These Data Processors, appointed by SelectAM, may include IT service providers, such as server providers and hosting services, accountants, lawyers or other service providers essential for the operational functionality of the Platform and Services in certain instances.

4.3 SelectAM exclusively engages Data Processors whose compliance with GDPR and other applicable privacy regulations has been validated by SelectAM, and who have contractually agreed to handle Personal Data in accordance with the applicable laws.

5.) COOKIES AND WEB TECHNOLOGIES

5.1 Our Platform uses Cookies which are small text files containing information stored on the computer and used for tracking or identification. Cookies store information about how you use an online service so that the Platform can recognize your device, provide functionality, enhance your experience, analyse usage patterns, and personalise content. For additional information on cookies, please visit www.allaboutcookies.org

5.2 How can I control cookies on my browser? You can also configure your browser at any time to be notified of the receipt of a cookie, so that you can decide whether you want to accept it or not. As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser's help menu for more information. The following is information about how to manage cookies on the most popular browsers:

a. Chrome

b. Firefox

c. Safari

d. Edge

5.3 What about other tracking technologies, like web beacons? Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Website. This allows us, for example, to monitor the traffic patterns of users from one page within a Website, to deliver or communicate with cookies, to understand whether you have come to the Website from an online advertisement displayed on a third-party website, to improve Website performance, and to measure the success of our current/future marketing campaigns.

5.4 Please check our Cookie Policy for further information and for information regarding specific types of cookies that the Platform uses.

6.) RIGHTS OF THE DATA SUBJECT

6.1 SelectAM shall ensure the fulfilment of all the rights of the data subject arising from the Applicable Laws.

6.2 In particular, regardless of what country you are located in, we respect your data subject rights. At SelectAM we implement privacy globally and we will not discriminate against you for exercising your privacy rights. Specifically, if you are in the European Economic Area and the UK you have the following rights under the GDPR and the UK GDPR:

a. Right to access: Subject to certain exceptions, you have the right to request a copy of the Personal Data we are processing about you, the information about categories of information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties to which we disclose your information.

b. Right to rectification: the right to request from SelectAM the supplementation or rectification of your Personal Data if these are insufficient, incomplete or inaccurate;

c. Right to object: the right to submit objections to SelectAM concerning the processing of one’s Personal Data, for example if the Personal Data is processed on the basis of the legitimate interests of SelectAM;

d. Right to erasure (right to be forgotten): the right to request the erasure of Personal Data, for example, if the Personal Data are processed based on the Data Subject’s consent and the Data Subject has withdrawn their consent;

e. Right to restriction of processing: the right to request from SelectAM the restriction of processing of Personal Data under the Applicable Law, for example, where SelectAM no longer needs the Personal Data for the purposes of the processing or where the Data Subject has objected to processing;

f. Right to withdraw the consent for processing Personal Data: If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge This includes cases where you wish to opt out from marketing messages that you receive from us. For any processing that is based on your consent, you can withdraw that consent at any time. This means that we will stop that processing, unless there is another basis to continue processing, such as a legal obligation. Withdrawing consent does not affect any processing that has already taken place;

g. Right to data portability: the right to receive from SelectAM the Personal Data that the Data Subject has provided to and which are processed on the basis of the Data Subject’s consent or for the performance of a contract concluded with the Data Subject, in writing or in a generally used electronic format and, if technically possible, request that SelectAM transfers these data to another Data Controller;

h. Right to avoid automated individual decision-aking: At SelectAM, all decisions that could affect your rights are made by humans. While we use computers to help us in our work, all decisions are made by real individuals.

i. Right to lodge a complaint: If the Data Subject is of the opinion that the processing of their Personal Data has violated their rights, they have the right at any time to file this claim to the Data Protection Ombudsman at tietosuoja(at)om.fi. For more information please visit https://tietosuoja.fi/en/home. You may additionally access the list of local data protection authorities in the European Union Member States here and the contact details of the ICO here. To exercise the rights pertaining to the processing of Personal Data or to submit requests concerning the processing of Personal Data, please contact us using the contact details provided at the end of this Privacy Policy

6.3 To exercise the rights pertaining to the processing of Personal Data or to submit requests concerning the processing of Personal Data, please contact us using the contact details provided at the end of this Privacy Policy. If you contact us to exercise any of the rights above we will check your entitlement and respond in most cases within 1 month.

6.4 While it is our policy to respect the rights of data subjects, please be aware that those rights are not absolute and they are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your Personal Data to defend our legal rights or meet our legal and regulatory obligations.

6.5 We may have disclosed your Personal Data as described in section 3 during the preceding 12 months, but we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your Personal Data to third parties in exchange for monetary or other valuable consideration.

7.) SECURITY OF PERSONAL DATA

7.1 SelectAM endeavours to implement reasonable technical and organisational security measures in an effort to safeguard the Personal Data in our custody and control. Such measures include, for example, limiting access to Personal Data only to our staff and authorised service providers on a need-to-know basis for the purposes described in this Privacy Policy, staff training as well as other administrative, technical, and physical safeguards.

8.) CHANGES TO THIS PRIVACY POLICY

8.1 We reserve the right to update this Privacy Policy to make sure it accurately reflects our data collection and use practices, our new features, or as applicable laws require. We will comply with applicable legal requirements regarding providing you with notice and/or consent when we make such changes, depending on the type of change made. Where it is practicable, we will notify you by email of any significant changes. However, the last update date is displayed above, and we encourage you to review this Privacy Policy periodically to be informed of how we use your Personal Data.

8.2 Our Platform may contain links to other websites which are controlled by third parties. These links are not an endorsement, authorization, or representation that we are affiliated with that third party. We do not have control over such websites and services and cannot be held accountable for their actions. Please be aware that these third party websites are governed by their own privacy policies.

What if I still have questions?

We hope that this Privacy Policy can resolve any query or concern you raise about our use of your Personal Data. If you feel we have not handled your query or concern to your satisfaction you can contact us by sending an email to privacy@selectam.io or by post to:

SelectAM Oy,

Lapinlahdenkatu 16, 00180 Helsinki, Finland.