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CORPORATE BUSINESS PRIVACY POLICY
September 2019
This policy is provided on behalf of F‑Secure Corporation and explains the
processing of your personal data by companies belonging to F‑Secure's group of
companies. It sets out how the personal data that we collect from you, or that
you provide to us, will be processed by us.
The data controller for this policy is F‑Secure Corporation, a Finnish company
with business ID 0705579-2. Our contact information can be found at the end of
this policy.
The personal data of individuals discussed in this policy is primarily collected
because F‑Secure is in, or is seeking to enter in, a commercial relationship
with the entities you are employed by.
The collected information and its use varies based on whether we have a
pre-existing, commercial relationship between F‑Secure and your employer (see
section for CUSTOMERS AND PARTNERS) or we have no prior engagement with your
employer (see section about MARKETING).
MARKETING
WHAT KIND OF DATA WE COLLECT ON YOU
From persons visiting our website, we acquire data on the device used, your IP
address, the route by which you arrived at our website, and your activities
therein, as well as any information you have submitted to us through forms. For
more detailed information, see our website privacy policy.
If you provide us your data via forms – online or offline – we ask you the
following information: names of the person and company, email address, country,
industry, size of company, telephone number, and area or service of interest.
We may also collect your information via our discussion boards or other social
media hosted by F‑Secure, competitions, promotion, surveys, webinars, and other
such events or points of interaction.
If you have been identified as a decision maker or influencer by a third party,
or listed as such in public sources, we typically obtain the following
information on you and the organization that you represent: company name, title,
name, function, language, email, zip code, city and state, country, phone
number, industry, turnover, and size of company.
We may aggregate such data with general data on your organization.
FOR WHAT PURPOSES DO WE USE IT
We collect and process the data so that we can, based on your position in your
organization, send you information relating to the services, conduct customer
surveys, arrange competitions, advertise and market our services (both
personalized and in aggregate), and share information and know-how about cyber
security and on our services. We also make use of the collected data in market
research, product and service development, and business offering development.
Should you or the organization that you represent become our customer, we
combine data collected at this pre-sales phase for you when your organization
becomes our customer. In such cases, we use it in accordance to the same
practices that we employ with the representatives of our corporate customers and
partners.
LEGAL GROUNDS
We collect data on individuals in influential, decision-making positions in
companies that would benefit from our services. We consider such activity to be
in the legitimate interests of both F‑Secure as a vendor and your employer as a
buyer.
Where legitimate interest is not suitable or applicable to a type of data
processing, we will seek your consent. For example; consent is the legal grounds
for data that we collect on your browsing of our websites. Where we base our
processing on consent, you may withdraw your consent at any time.
CUSTOMERS AND PARTNERS
WHAT KIND OF DATA WE COLLECT ON YOU
Regarding individuals, with whose employers we are in a commercial relationship,
we process the following personal data on you: your name, your position / role /
title, your email address and phone number, which legal entity that has
purchased the license or service, such entity’s street / mailing address,
country, your language and messaging preferences, available LinkedIn
information, relevant access credentials to and logs in our systems.
F‑Secure collects this data:
* Via marketing activities (more information under Corporate Business -
marketing),
* Via our website, our discussion boards or other social media hosted by
F‑Secure,
* Via competitions, promotion, surveys, webinars, and other such events or
points of interaction,
* Through sales, support, and account management activities, and
* Through partner sales and customer management activities (e.g. a partner
orders a license to an end customer or changes an end customer’s
information).
FOR WHAT PURPOSES DO WE USE IT
We collect and process the data so that we can manage our customer
relationships, provide you with information, products and services that you
request from us, run joint planning sessions, analyze the data for business
development purposes, deliver license certificates, undertake all steps of order
fulfillment and payment processes, perform personalized marketing activities,
communicate in relation to both the initial sales of our services as well as
license and service renewals, our other offerings and other relevant
information, collect your feedback and identify authorized users for selected
systems and administer user accounts, and provide help and support for the
services.
As you may approach us or submit information to us via multiple channels – such
as our resellers, events, or website – we combine such information to make our
communications relevant to your needs.
LEGAL GROUNDS
F‑Secure has a legitimate interest to process personal data of the employees of
its customers and partners to enable and facilitate provisioning its commercial
services to its corporate customers and partners, including undertaking relevant
sales and marketing activities as enabled by applicable laws on different forms
of marketing-related communications.
Where processing is required for an activity, it is necessary that we are able
to process the required data. This is the case e.g. when we need to effectively
communicate with the representatives of our partners and customers, deliver and
invoice the agreed services, respond to an enquiry or support request, or enable
your participation in our corporate customer beta program.
Where legitimate interest is not suitable or applicable to a type of data
processing, we will seek your consent. For example; consent is the legal grounds
for data that we collect on your browsing of our websites. Where we base our
processing on consent, you may withdraw your consent at any time.
PROFILING
To keep our interaction focused on the services that you are primarily
interested in, some of the data that we collect may be based on your activity on
our corporate web pages. This occurs in the event that you have consented to
having such traffic linked to you, for example by filling any of our web forms.
We do not record your web traffic outside F‑Secure websites. The more activity
and interest you show towards our solutions, the more likely it is that we will
approach you. This is elaborated in our cookie banners and in our website
privacy policy.
If you do not wish us to have your email address for this purpose, you may
freely request that we remove it from our records. The impact on you is that the
messaging that you may receive from us may be less relevant for you and your
employer.
We do not disclose such profile information to external parties. We may share
general data on your interest with our reseller to better serve your needs (e.g.
to enable you to purchase via our local reseller), but only in the event that we
have actually started sales negotiations.
TRANSFERS AND DISCLOSURES
Personal data is primarily processed by F‑Secure's local company that you are
interacting with the most. In addition to local processing, the most common
reason for exchange of information between different F‑Secure offices is to
enable us to efficiently serve you and manage our relationship. See the list of
our local country offices here).
Personal data can also be made available to F‑Secure's channel partners when -
and to the extent that - disclosure of data is necessary for the relevant
purposes of processing data (listed above). For example, if you are interested
in purchasing our services, we provide such information to our reseller partner
in the area.
Some of F‑Secure's affiliated companies, subcontractors, and distributing
partners are located outside the European Economic Area (EEA). Even if the data
is stored within the EEA, it may also be processed by our staff operating
outside the EEA who work for us or for one of our suppliers. Such staff may be
engaged in, among other things, the fulfilment of your order, the processing of
your payment details, and the provisioning of support services.
Where personal data is transferred from the EEA to outside the EEA, F‑Secure
undertakes to safeguard the security and integrity of processing by implementing
the appropriate measures as required by law, and by imposing appropriate
contractual safeguards on such data importers (for example by adhering to data
transfer clauses approved by the European Union).
Advertisers and advertising networks that require the data to select and serve
relevant advertisements to you and others are listed on our website privacy
policy.
THIRD PARTIES
We also work closely with third parties (including, for example, business
partners, subcontractors in technical, payment, and delivery services,
advertising networks, analytics providers, search information providers, credit
reference agencies) and may receive information about you from them. These
vendors have collected this information from private or public sources or
directly from you.
OTHER USES AND DISCLOSURES
Information on secondary purposes for which personal data may occasionally be
processed.
Learn more
There are circumstances not covered by this privacy policy where the use or
disclosure of personal data may be justified or permitted, or where we may be
obligated by applicable laws to disclose information without acquiring your
consent or independent of service provisioning.
One example includes complying with a court order or a warrant issued by the
authorities in the relevant jurisdiction to compel the production of
information.
Similarly, there may be other circumstances where there is a justifiable
legitimate interest to disclose limited sets of information to a third party.
Examples of such disclosures include cases where we need to protect ourselves
against liability or to prevent fraudulent activity, where it is necessary to
solve or contain an ongoing problem, or where we need to meet the legitimate
information requirements of our insurers or governmental regulatory agencies. In
any such action, we will act according to the applicable laws.
We may also need to transfer your personal data as part of a corporate
transaction, such as a sale, merger, spin-off, or other corporate reorganization
of F-Secure, where the information is provided to the new controlling entity in
the regular course of business. F-Secure group discloses and transfers data
internally as required by our then current operational model. We do, however,
limit the disclosures internally to only those group companies, units, teams,
and individuals who have a need to know such information for the intended
purposes of processing it.
We weigh each disclosure requirement carefully and take the possibility of such
disclosure requests into account when deciding where and how we store your
personal data.
RETENTION
On a monthly basis, we purge our direct marketing records from all contacts who
have not reacted to our messaging or visited our web pages during the last 24
months and who are not affiliated with any of our customers or partners.
If you become our customer or partner, the data is retained for the duration of
your organization's relation. User data in our corporate customer registry is
stored for the duration of the license/subscription/engagement and up to five
years after the last engagement or subscription with the customer or partner has
expired.
SECURITY
Information on the security practices that we employ to keep your data secure.
Learn more
We apply strict security measures to protect the confidentiality, integrity, and
availability of your personal data when transferring, storing, or processing it.
We use physical, administrative, and technical security measures to reduce the
risk of loss, misuse, or unauthorized access, disclosure, or modification of
your personal data.
All personal data is stored on secure servers operated by F‑Secure or our
partners with access limited to authorized personnel only.
YOUR RIGHTS
Information on your statutory rights and how to contact us.
Learn more
You have the right to the data that we have on you. In particular, you have the
following rights to the personal data that we hold on you:
* Access and rectification. You have the right to ask us what personal data we
have on you and to get a copy of the data that we can identify pertaining to
you in this context. Should you find any errors (e.g. obsolete information)
in such data, we urge you to contact our customer care to resolve the issue.
Some of our service portals allow you to update your customer information.
For such, you should update any changes to your personal data, for example
change of address or email address. If you cannot update the changes
yourself, you may inform us of the necessary changes.
* Objection. You are entitled to object to certain processing of personal data,
including for example the processing of your personal data for marketing
purposes or when we otherwise base our processing of your data on a
legitimate interest. In the latter case, you need to establish a legally
valid rationale for your objection.
* Right to be forgotten. You also have the right to request us to cease storing
your personal data and erase it. In this case you need to establish a legally
valid rationale for your request.
* Portability. You also have the right to ask for personal data that you
yourself have provided — pursuant to a contract or your consent. You may
request the data in a structured, commonly used, and machine-readable format
and further that the data is transmitted to another controller, where
technically feasible.
* Withdrawing consent. In cases where the processing is based on your consent,
you have the right to withdraw your consent at any time via relevant
settings. For identifiable service analytics data, you can find the settings
in the service user interface. You also have the right to opt out from our
marketing communications via the preference center accessible through the
link.
* Restriction. If you establish that the data we have on you is incorrect or we
have no legal right to use it, you may request that we cease any further
processing of your personal data, and merely keep it in store until the issue
is resolved.
You can exercise your rights via our customer care function. The links to
contact us are in the “Contact information” section.
Note that there may be situations where our confidentiality obligations, our
right of professional secrecy, and/or our obligations to provide our services
(e.g. to your employer) may prohibit us from disclosing or deleting your
personal data or otherwise prevent you from exercising your rights. Your above
rights are also dependent on the legal grounds based on which we process your
personal data.
If you have any complaints about how we process your personal data, or would
like further information, please contact us at any time. If you feel that we are
not enabling your statutory rights, you have the right to lodge a complaint with
a supervisory authority. In most cases, this authority is the Finnish Data
Protection Ombudsman (www.tietosuoja.fi).
CONTACT INFORMATION
If you have any questions or concerns about the matters discussed in our privacy
policies, please contact:
F‑Secure Corporation
Tammasaarenkatu 7
PL 24
00181 Helsinki
Finland
How to contact us:
* If you are a client of our consumer line of products, please contact us
via our consumer support channels.
* If you are a client of our corporate line of products, please contact us
via corporate support channels.
* You can contact F‑Secure’s Data Protection Officer by sending a message to
privacy@f-secure.com. If you wish to exercise your rights as a data subject,
please use the above links instead.
GENERAL
Information on definitions and change management.
Learn more
DEFINITIONS
This is what we mean when we make certain references within this policy.
“Client”, “you”, refers to a private or corporate user or any other data
subjects who buy, register for use, or use our services, whose devices and data
traffic are protected by our services, or who may have submitted personally
identifiable information to us. This information may have been submitted through
the use of our services, websites, telephone, email, registration forms, or
other similar channels.
“Personal data” refers to any information on private individuals that is
identifiable to them or their family or household members. This information may
include names, email and mailing addresses, telephone numbers, billing and
account information, and other, more technical information that can be linked to
you, your device, or the behavior of either, that we process while providing our
services.
“Services” refer to any services or products that are manufactured or
distributed by F‑Secure, including software, web solutions, tools, and related
support services.
“Website” refers to the f-secure.com website or any other website that F‑Secure
hosts or controls, including subsites and browser-based service portals.
CHANGES
This version of the policy clarifies, updates, and replaces the previous
version. To continue keeping this document up to date, we will make changes and
additions to this from time to time also in the future.
We will publish the changed policy document on our website or at another
interaction point where it has previously been made available. If the changes
are significant, we may also notify you by other means. Any changes will apply
starting from the date that we publish the revised policy document.
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