SKIPPERI’S PRIVACY NOTICE

Last updated: May 3, 2024


This privacy notice describes Skipperi, Inc.’s (“Skipperi”) customer privacy practices for our SKIPPERI branded global websites, SKIPPERI services, SKIPPERI  customer sales and marketing activities, and SKIPPERI  customer services and support functions, among others.  


This statement does not apply to SKIPPERI employee data practices. Please also note that certain SKIPPERI websites, or software experiences may have links to third-party websites or services.  In most cases, those third-party resources are subject to the privacy practices and policies of those third parties and not SKIPPERI.

With this Privacy Notice we provide you information on how and why we process your personal data in our business activities.

We process personal data in our business activities for the following purposes:

- Customer relationships

- Strong identification of customers

- Strategic analysis of customer data to develop services and fulfil customer needs

- Email marketing

- Postal marketing

- Business partner relationships

- Recruiting

- Communications

- Social media

- Cookies

- Legal obligations

The controller of your personal data is Harmaja 10 Oy (Business ID: 2789909-5), which is located at Veneentekijätie 6, 00210 Helsinki, Finland.

If you have any questions regarding the privacy notice, please contact our data protection officer at dpo@skipperi.fi.

1) WHAT TERMS ARE USED IN THIS PRIVACY NOTICE?

Controller means the party responsible for processing the personal data of the data subject.

Customer(s) means the party who rents the Boat, the party who is offering the Boat for Rental as well as the city boater.

Data subject is a term for a human being in accordance with data protection laws.

Legal basis for processing means the applicable legal ground on which the controller processes the data subject's personal data. 

Personal data means any information concerning the data subject or information by which the data subject can be identified.

Privacy notice means a document drawn up in accordance with applicable law, through which the controller informs data subjects of the ways their personal data is processed.

Processor means the party who processes personal data on behalf of the controller.

Purpose for processing means the reason why the controller processes the data subject's personal data.


2) WHY DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data in accordance with the processing purposes listed below. In the sections on processing purposes, you will find information on what personal data we process and on what legal basis we process your personal data.

Customer relationships

We process our customers’ personal data for customer relationship purposes, namely for performing the rental service and city boat service. For these purposes we process our customers’ contact details, date of birth data, pictures, bank account data, boating skill data and boat data.

The legal basis for processing is the performance of our contractual obligations.

Strong identification of customers

We process our customers’ personal ID’s for the purposes of strong identification of customers.

Strategic analysis of customer data to develop services and fulfil customer needs

We process our customers’ personal data to strategically analyze it to develop new services and fulfil customer needs. For these purposes we process our customers’ contact details, as well as information related to the use of our services.

The legal basis for processing is our legitimate interests, according to which we develop our services.

NB! You may have a right to object data processing for these purposes (see section concerning your rights).

Email marketing

We process personal data of our customers for email direct marketing purposes. For these purposes we process our customers’ contact details and information related to the use of our services.

The legal basis for processing is our legitimate interests, as marketing is provided to our customers. NB! You have a right to object data processing for these purposes (see section concerning your rights).


Postal marketing

We process personal data of boat owners included in public registers for postal direct marketing purposes. For these purposes we process the data subjects’ contact details.

The legal basis for processing is our legitimate interests, according to which we sell our services.

Business partner relationships

We process the personal data of our business partners for the purposes of business partner relationships. For these purposes we process the business partners’ contact details.

The legal basis for processing is the performance of our contractual obligations. 

Recruiting

We process the personal data of job applicants for recruiting purposes. For these purposes we process the job applicants’ contact details, CV information and other data disclosed to us.

The legal basis for processing is our legitimate interests, according to which we govern our recruiting practices.

NB! You have a right to object data processing for these purposes (see section concerning your rights). 

Communications

We process the personal data of people who contact us for communication purposes. For these purposes we process contact details and other data disclosed to us.

The legal basis for processing is our legitimate interests, according to which we govern our communication.

NB! You may have a right to object data processing for these purposes (see section concerning your rights).

Social media

We process the personal data of our social media contacts for social media purposes. For these purposes we process contact details.

The legal basis for processing is our legitimate interests, according to which we manage the contact requests made to us.

Cookies

We process IP address data of the people who visit our website for purposes concerning the use of cookies. Please see our Cookie Notice for more information.

Legal obligations

We process our customers’ contact details in order to be able to comply with applicable laws.

  1. FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data from different sources, depending on our purposes for processing personal data.

Customer relationships / Strong identification of customers / Email marketing We collect your personal data for these purposes from you.

Postal marketing

We collect your personal data for this purpose from different public registers, such as Traficom’s information systems.

Business partner relationships / Communications

We collect your personal data for these purposes from yourself, our business partners, the authorities, and different public sources, such as the trade register.

Strategic analysis of customer data to develop services and fulfil customer needs / Recruiting / Legal obligations

We collect your personal data for these purposes only from yourself.

Cookies

We collect your personal data by using cookies.

Children

Our websites, products and services are intended for adults aged 18 and older.  Typically, if we become aware that we have collected personal data from persons aged 17 and under, we will take appropriate steps to delete and purge that data.  If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.


  1. DO WE TRANSFER YOUR PERSONAL DATA?

We may transfer personal data to third parties as a normal course of our business. When personal data is transferred to third parties, we ensure that the transfers are carried out in a secure way and in accordance with adequate data protection agreements.

We may also transfer personal data to third countries. When doing so, we ensure an adequate level of data protection, e.g. by using standard contractual clauses issued by the European Commission, and other similar arrangements.

All personal data may be transferred to data storage and communications service providers. Personal data processed for the purposes of Strong identification of our customers may be transferred to service providers who provide strong authentication services, and personal data processed for the purposes of our Legal obligations may also be transferred to accounting and auditing service providers.

  1. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

The retention period of your personal data depends on the purposes for which we process your personal data. We inspect the necessity of the retained personal data regularly and keep records of the inspections.

Customer relationships / Strong identification of customers / Business partner relationships We retain personal data for as long as our contractual relationship is in effect.

Strategic analysis of customer data to develop services and fulfil customer needs

We retain necessary personal data for as long as it is necessary to fulfil the purpose of data processing. 

Email marketing / Postal marketing

We retain personal data for as long as it is relevant or until you prohibit us (i.e. opt out) from processing your personal data for direct marketing purposes, or when we find out that you no longer wish to receive marketing.

Recruiting

We retain the necessary personal data for a maximum of twelve (12) months from the receival day of the job application.

Communications

We retain the necessary personal data for three (3) years after the contact.
Social media

We retain information on our social media channels until individuals remove their information from the channels.

Cookies

The retention period depends on each cookie used.

Legal obligations

We retain data for as long as the applicable law requires us to retain data, including for tax and audit purposes.

6)  HOW CAN YOU REVIEW, CORRECT, AMEND OR DELETE PERSONAL DATA?If you have an account with us, you may have the ability to review, correct, amend or delete your personal data through your account profile.  To do so, please visit your account and click on “Settings”.


In addition, under this privacy notice and certain applicable laws, you may submit a request to us to review, correct, amend or to delete your personal data that we have about you.  You may also have the right to request a machine-readable copy of your personal data. To submit such a request to us, please contact us at dpo@skipperi.fi.


Please note that we will review, respond to and act upon such requests as soon as possible and in accordance with applicable laws.  We are also required to verify your identity before granting you access to your personal data.  If you have account with us, we may verify your identity by requiring you to sign into your account. If you do not have an account, or an email address on file with us, then we may request additional limited information from you in order to verify your identity. Please note that if you do not have an account with us, or an email address on file, or if we are unable to verify your identity in our records, we may deny your request.


You may also use an authorized agent to submit a request under this section on your behalf. If you choose to have an authorized agent submit such a request on your behalf, we  will require: (i) You to provide the authorized agent written permission to do so; and (ii) your agent to verify their identity directly with us.  We may deny a request from an agent that does not meet these requirements.


In addition, you have the right to raise questions or complaints with your applicable national data protection authority at any time.

7) HOW DO WE PROTECT PERSONAL DATA?

We believe that privacy and security go hand-in-hand.  We use appropriate physical, technical, and administrative controls to protect the personal data we are responsible for.  That includes encryption and other enhanced security measures, where appropriate or required.  We also take appropriate steps to make sure that our vendors, suppliers and certain other partners adopt consistent standards of protection for the personal data that we are responsible for.   

However, it is important to note that no technology is guaranteed to be invulnerable to threat or attack.  Therefore, please be sure to exercise care when using any website or product.  If technology you use is configured with privacy or security controls or features, please be sure to utilize those.


8) DO WE SELL PERSONAL DATA? 


While we may share personal data we collect pursuant to the purposes described above in section 2, we do not sell personal data.  If we did decide to sell personal data at any point, we would provide appropriate notice and consent mechanisms to individuals as required by applicable laws. 

In addition, please note that if we or any of our businesses or operations were to be sold to another entity at any point, that sale could involve the transfer of personal data held by us to the acquiring organization.  In such a circumstance, we would provide appropriate notice and consent mechanisms to individuals as required by applicable laws.

8) CAN THIS PRIVACY NOTICE BE AMENDED?

We may unilaterally amend this privacy notice. We update the privacy notice as necessary, for example, when there is a change in legislation. Amendments to this privacy notice will take effect immediately when we post an updated version on our website.

If we make significant changes to the privacy notice, or if there is a significant change in the way it is used, we will notify the data subjects.

In all events, Dealer shall comply with any specific privacy laws applicable to the jurisdiction in which the Dealer is operating the boats or doing business. 

(Last update 1.5.2024)